1

UNITED STATES DEPARTMENT OF ENERGY
 

PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE
 

FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND
 

GENERAL SERVICE INCANDESCENT LAMPS
 

AND
 

ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE
 

FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS
 

U.S. Department of Energy
 

Room 8E­089
 

1000 Independence Avenue, Southwest
 

Washington, D.C.
 

Monday, March 10, 2008

9:00 a.m.

Participants

DOUG BROOKMAN, Facilitator

LINDA GRAVES
 

Department of Energy
 

STEVE NADEL

American Council for an Energy Efficient

Economy

RON LEWIS
 

Department of Energy
 

GARY FERNSTROM
 

Pacific Gas and Electric
 

MICHAEL SCHOLAND
 

Navigant Consulting, Inc.
 

CONAN O'ROURKE
 

Lighting Research Center
 

JOE HOWLEY
 

GE Consumer and Industrial
 

MAHIMA GUPTA
 

Navigant Consulting, Inc.
 

ANDREW DELASKI

Appliance Standards Awareness Project

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Participants (Continued)

PAM HORNER
 

Osram Sylvania
 

NEMA Lamp Section
 

PAUL WALITSKY
 

The Industrial Ecology Company, LLC
 

MIKE RIVEST
 

Navigant Consulting, Inc.
 

JEFF HARRIS
 

Alliance to Save Energy
 

SUSAN ANDERSON
 

Osram Sylvania
 

KEITH COOK
 

Philips Lighting
 

TOM ECKMAN
 

Northwest Power and Conservation Council
 

DIANA BURK
 

Navigant Consulting, Inc.
 

DAIN HANSEN
 

National Electric Manufacturers Association
 

ERIC STAS
 

Department of Energy
 

FRANCINE PINTO
 

Department of Energy
 

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A G E N D A
 

AGENDA ITEM: PAGE:

Welcome 5

Linda Graves

Opening Remarks, Introductions and Agenda Review 6

Doug Brookman

Test Procedure Overview 13

Michael Scholand

Comments from Participants Regarding

Procedure NOPR

the Test 15

(None)

Test Procedures 16

Michael Scholand

Conan O'Rourke

Energy Conservation Standard Overview 52

Mahima Gupta

Comments from Participants Regarding

Conservation Standard ANOPR

the Energy 54

Andrew Delaski

Appliance Standards Awareness Project

Scope of Coverage 60

Michael Scholand

Engineering Analysis 75

Mahima Gupta

Conan O'Rourke

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A G E N D A
 

AGENDA ITEM: PAGE:
 

Afternoon Session

Engineering Analysis (Continued) 111

Conan O'Rourke

Mahima Gupta

Life­cycle

Analysis

Cost Analysis and Payback Period 191

Diana Burk

National Impact Analysis 241

Mahima Gupta

Closing Remarks 299

Ron Lewis

Adjourn

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1 P R O C E E D I N G S

2 9:20 a.m.

3 Welcome

4 Linda Graves

MS. GRAVES: Good morning. Welcome to the

6 Department of Energy. I'm Linda Graves. I'm the

7 leader of the Standards Lighting Team. I'm here with

8 my boss, representatives of general counsel and policy,

9 and a team of energy consultants. It's a high­energy

group from Navigant Consulting, Rensselaer Polytechnics

11 Lighting Research Center, and OnLocation, and they will

12 be doing the presentations. They have quite a list of

13 issues that they'd like your input.

14 We're doing this as a doubleheader. We're

doing a combined meeting with the test procedures on

16 incandescent, fluorescent, and reflector lamps,

17 followed by the standards on fluorescent lamps and

18 reflector lamps. We've asked our esteemed facilitator

19 to be flexible as we work through the agenda so we can

cover the material in a way that will meet everyone's

21 needs.

22 As you know, the Energy Independence

23 Securities Act had a large impact on the team. We were

24 on the homestretch of being ready to go forward with

these rulemakings, and our team has really done yeoman

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1 effort to incorporate all the changes very quickly.

2 For those of you who participated in the

3 framework document meeting, you'll recognize that the

4 scope has changed. We very much appreciate the impact

you gave us at that meeting and look forward to your

6 input and participation in this meeting today.

7 With that, I'm going to turn it over to our

8 facilitator, Doug Brookman.

9 Opening Remarks, Introductions, and Agenda Review

Doug Brookman

11 (PowerPoint presentation.)

12 MR. BROOKMAN: Thank you. It's our tradition

13 to ask that each person introduce him­ or herself, so

14 I'm going to start and go around the room. Your name

and organizational affiliation, please.

16 (Introductions.)

17 MR. BROOKMAN: I guess that's all that's with

18 us. We expect more people will be joining us.

19 Probably, they're trying to clear through security.

I think all of you received a packet of

21 information as you walked in the door. The top of the

22 packet is the agenda for today, followed by a colorful

23 packet of slides that you'll be seeing as the day

24 proceeds, the PowerPoint presentation, as well as some

issues that have been identified for stakeholder

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1 comment.

2 As Linda said, this is both the test

3 procedure meeting and also the standards meeting for

4 general service fluorescent lamps and incandescent

reflector lamps. So we're going to be covering both of

6 those in the span of these two days.

7 I'm going to take a quick spin through the

8 agenda. I am now finishing the first substantive block

9 that you see there, 9:05 to 9:15. Following that,

we're going to have a brief test procedure overview.

11 Immediately following that overview there's an

12 opportunity for each of you that wishes to do so to

13 make brief overview comments. Any issues that are

14 especially of concern to you, issues you want to flag

for the Department's consideration, that would be a

16 good time to do it. But, they should be brief.

17 Following that, we will have a summary

18 presentation on test procedures. We'll take a break

19 mid morning, round about 11:15 or so, and then,

following that, we'll have an Energy Conservation

21 Standard Overview and then get additional comments from

22 participants regarding the Energy Conservation Standard

23 ANOPR. We'll break for lunch round about noonish,

24 12:15.

Following that, when we return from a lunch,

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1 a summary on scope of coverage, a mid afternoon break,

2 and then close out the day with engineering analysis.

3 And then you'll see, round about 3:45 this afternoon,

4 there's an opportunity again for anybody that wishes to

make comments that you don't think have been covered

6 sufficiently or at all. That would be a time for you

7 to raise additional issues. We'll adjourn today round

8 about 4 o'clock.

9 Let me say, as we're going through the agenda

today there's quite a bit of content. We'll be going

11 as efficiently and effectively through it as we can.

12 We don't want to diminish anyone's opportunity to speak

13 and comment. However, if we have the opportunity ­­

14 we'll keep it moving along, is the bottom line.

So I'm asking each of you to speak up and be

16 assertive, and I'll be trying to recognize individuals

17 by name and queue you to be speaking. The Department

18 of Energy and I don't believe in wasting anybody's

19 time, so we'll go as rapidly through this and not

diminish the effectiveness of this meeting.

21 Steve Nadel, before I finish the agenda

22 review?

23 MR. NADEL: Yes. I was wondering, based on

24 some past experience, whether potentially things might

go well we can try to do this in one day. If we have

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1 to go to 5 o'clock or something.

2 MR. BROOKMAN: Ron Lewis, do you want to

3 speak?

4 MR. LEWIS: We're going to deal with the

standards and the test procedures over the two days.

6 There are people that expected it to go into tomorrow

7 and some of them aren't even here yet. So I don't

8 expect we're going to get both of them done in one day.

9 MR. NADEL: Okay. Some of us can't come

tomorrow, but I guess we'll just proceed. I'm just

11 saying let's let the discussion proceed and if we can

12 cover more, is there a problem with that.

13 MR. LEWIS: If we finish ­­ there's a lot to

14 do. I would be surprised. But I think there were some

people that couldn't make it today that were going to

16 try to make it tomorrow and catch the end.

17 MR. FERNSTROM: I guess I would add, there

18 were some of us that saw in the notice that this was

19 going to be a one­day meeting, too, and we believed

that.

21 MR. LEWIS: Well, if we finish, but I don't

22 want to rush it and compress it trying to finish it in

23 one day if that's not the natural ending. That's, I

24 guess, my point, was not trying to just hurry things

only to complete it in one day.

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1 MR. BROOKMAN: So one thing I have ­­

2 MR. FERNSTROM: I'm sorry. I thought I

3 understood you to say absolutely not.

4 MR. LEWIS: Yeah. No, that was not my

intent.

6 MR. BROOKMAN: One thing that I haven't

7 covered yet because I'm still doing the agenda review

8 is some basic ground rules. We do hope that you'll say

9 your name for the record as we proceed so that our

court reporter here can get it straight. So that was

11 Steve Nadel, Ron Lewis, and then followed by Gary in

12 that, and followed again by Ron Lewis.

13 So the bottom line, Ron, is however far we

14 can get today, that's okay.

MR. LEWIS: Yes. I just don't want to rush

16 it and not cover the things with the focus being to end

17 it today.

18 MR. BROOKMAN: Let me offer a hypothetical.

19 If we got through everything today, would we come back

tomorrow?

21 MR. LEWIS: You can if you want.

22 (Laughter.)

23 MR. BROOKMAN: No, for real, because there

24 may be some people that maybe are going to show up

tomorrow.

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1 MR. LEWIS: We'll make arrangements if we do

2 complete everything, but I was under the impression

3 that we had so much content and there were some people

4 that said that they couldn't make it for the first day

and would try to make it for the second.

6 MR. BROOKMAN: We have a lot of content here.

7 We don't want to diminish anybody's capacity to

8 comment.

9 Okay. We appreciate these comments along

these lines. So then we'll go as quickly as we can,

11 and having said that, if we don't get it all done

12 today, then we'll resume tomorrow at 9 a.m. as we did

13 today. We'll observe basically the same format, and

14 we'll cover some of the material that we covered today

briefly.

16 So you can see the Energy Conservation

17 Standard Overview at 9:15. Round about 9:30 we go to

18 Life­cycle Cost Analysis. We'll take a break mid

19 morning. Then we'll go to National Impact Analysis.

We'll break for lunch, and then discussion of other

21 issues, talk about the NOPR analyses, and then talk

22 about next steps and closing remarks. If this schedule

23 holds, we'll adjourn tomorrow at about 3:30 or so.

24 So that's the general plan. Questions and

comments on that?

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1 (No response.)

2 MR. BROOKMAN: There's frequently a slide for

3 ground rules, but I didn't see it in there.

4 MR. SCHOLAND: Sorry, Doug.

MR. BROOKMAN: That's okay.

6 MR. SCHOLAND: It's in the ANOPR stack.

7 MR. BROOKMAN: So I'm going to ask simply

8 that you speak one at a time and also say your name for

9 the record. Listen as an ally. Keep the focus here.

That is, please turn off your cell phones, put them on

11 vibrate, whatever. And if you have to have a sidebar

12 conversation, you'll notice the acoustics in this room

13 are very good.

14 (Laughter.)

MR. BROOKMAN: We can hear you. And it will

16 be disruptive if you're involved in a lengthy sidebar

17 conversation. So please don't do that. Please keep

18 the focus here.

19 I hope this is an opportunity for you to

pursue the issues that matter to you today. Let's

21 seize this opportunity today and make this a useful day

22 of dialogue for you and for the Department.

23 Okay. So that's all that I would say at the

24 outset. I think the first item on the agenda is then

to have a test procedure overview. Michael Scholand.

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1 MR. SCHOLAND: That's right. Thanks, Doug.
 

2 Test Procedure Overview
 

3 Michael Scholand
 

4 (PowerPoint presentation.)
 

MR. SCHOLAND: Mike Scholand from Navigant

6 Consulting. I'm going to walk you through some of the

7 slides here on the test procedure notice of proposed

8 rulemaking that the Department issued a couple of weeks

9 ago. My colleague Conan O'Rourke and I will be tagteaming this presentation because it is, after all, the

11 Monday morning after the hour has changed and it's a

12 little hard to have one person do them all. It might

13 put you to sleep.

14 So, what is the purpose of today's meeting.

Okay. We have four goals for today that we outline

16 here on Slide Number 2: to

17 proposed test procedure for

18 incandescent lamps, to seek

19 on the proposal, to discuss

that proposal, and finally,

21 this rulemaking.

present the Department's

fluorescent and

comment from participants

specific issues relating to

to discuss next steps in

22 Let's review the schedule for the test

23 procedure. The NOPR, as I mentioned, was issued by the

24 Department on February 21st, 2008. The public meeting

we're holding today. Comments on the NOPR from

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1 interested parties we're going to be recording. As

2 Doug has mentioned, a court reporter is here today.

3 All your comments that you make about the notice of

4 proposed rule will be recorded in the transcript for

today's meeting, and there is also a 75­day comment

6 period for written comments which you can supply to the

7 Department.

8 I just want to confirm, Linda. The notice of

9 proposed rulemaking will be published on Wednesday; is

that what the Federal Register said?

11 MS. GRAVES: The 13th.

12 MR. SCHOLAND: The 13th? Okay. So that's

13 Thursday? It's Thursday. So the 75 days will start

14 from the 13th. I think that puts us sometime in May,

towards the end of May.

16 DOE obviously reviews and considers all

17 comments, and finally, there will be a final rule

18 published. That final rule for the test procedure will

19 be published either on the same day or before the

notice of proposed rulemaking for the Energy

21 Conservation Standard, which is the second presentation

22 we'll be going with today.

23 I want to briefly walk you through the

24 outline for the test procedure presentation before we

open up the floor for any opening statements. We have

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1 eight issues we're going to be discussing this morning,

2 Conan and myself. The first is updates to the test

3 procedure references. Then we'll talk about high4 frequency fluorescent ballasts. We'll talk about

rounding fluorescent lamp efficacy. We'll talk about

6 the measurement of correlated color temperature. We'll

7 talk about general service fluorescent lamp basic model

8 definition.

9 Conan will discuss the reference ballast

settings for added fluorescent lamp coverage, and we'll

11 discuss test procedures for general service

12 incandescent lamps and off mode and standby mode energy

13 consumption. So these are the eight issues we'll be

14 talking about this morning in this set of slides.

Let's just stop here and open up for any

16 comments or issues or opening statements from any

17 stakeholders here on the test procedure.

18 Comments from Participants Regarding the Test Procedure

19 NOPR

MR. BROOKMAN: This is an opportunity for

21 anybody that wishes to say anything briefly that they'd

22 like to call out and call attention to.

23 (No response.)

24 MR. BROOKMAN: I see no comments, then, at

this time. Okay.

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1 Test Procedures

2 Michael Scholand and Conan O'Rourke

3 (PowerPoint presentation.)

4 MR. SCHOLAND: Okay. Great. Moving right

along, let's walk through some background on the

6 regulatory history for the test procedure. As you all

7 know, fluorescent and incandescent lamps were added to

8 EPCA by the Energy Policy Act of 1992 and DOE

9 established a final rule for that test procedure in May

of 1997. That established test procedures for

11 incandescent and fluorescent lamps, including compact

12 fluorescent lamps. The test procedure incorporated by

13 reference several ANSI and IESNA ­­ that's the

14 Illuminating Engineering Society of North America ­­

industry standards.

16 Then, in August of 2005, Congress passed the

17 Energy Policy Act of 2005, and DOE codified a test

18 procedure final rule in December of that year which

19 established the Energy Star Version 2.0 for medium

screw­base compact fluorescent lamps as the test method

21 for CFLs.

22 Finally, the Energy Independence and Security

23 Act of 2007 established energy conservation standards

24 for general service incandescent lamps and it also

directed DOE to incorporate a measure of standby mode

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1 and off mode energy consumption in its test procedures.

2 That's kind of the regulatory overview for

3 the context. Are there any questions at this point?

4 MR. BROOKMAN: I wasn't clear because I was

trying to be brief earlier. The format, as you can

6 see, is that there's rather detailed information in

7 these slides. After a few of the slides, then there's

8 an actual opportunity for each person to comment as you

9 wish. So you could just find the spot that's most

relevant for you and make your comments.

11 MR. SCHOLAND: Okay. No questions on this

12 regulatory history? Then I'll hand it over to Conan.

13 MR. O'ROURKE: Thank you, Michael. The first

14 thing we're going to go over is updates to the test

procedures, the references in particular.

16 We've looked at the references for the

17 existing ANSI standards that were lamp standards and

18 during this process we ­­ it's been identified that

19 these standards have been updated and also compiled

differently. The first row here is showing the

21 previous ANSI standards from 1991 have been

22 consolidated for double­ended lamps into C78.81 and for

23 single­ended lamps for C78.901.

24 Also, the test method for electrical

measurements of fluorescent lamps has also been updated

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1 to the 1997 version, and the reference ballast ANSI

2 standard has also been updated to the 2002. Some of

3 these standards show up in the definitions of cold

4 temperature fluorescent lamp and fluorescent lamp, the

first row in particular, and also rated wattage refers

6 to them. Parts of the CFR that deal with references

7 and also the test procedure itself will reflect these

8 updated standards.

9 IESNA and the CIE standards have also been

addressed. LM­9, which deals with electrical and

11 photometric measurements of fluorescent lamps, has been

12 updated to a 1999 version. LM­45, which deals with the

13 measurements of incandescent lamps, has been updated to

14 the 2000 version. It was previously LM­16, which had

been withdrawn. It was no longer part of the IES

16 procedures. And also, an update to CIE 13.2. It has

17 been corrected to 13.3, which is dealing with the

18 color­rendering properties of light. This does affect

19 the definition of colored fluorescent lamp and also

would be addressed and referenced in the test procedure

21 section in Appendix R.

22 Any questions on those test procedures at

23 all?

24 (No response.)

MR. O'ROURKE: I'm going to continue on to

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1 talk about the medium base compact fluorescent lamp.

2 In the 1997 rule, they had established test procedures

3 for CFLs in Appendix R and it had referred to LM­66.

4 But in EPACT 2005 it had been updated to Version 2.0 of

the Energy Star specification for CFLs. So to prevent

6 any conflict it's being suggested that LM­66 be removed

7 as a reference in the test procedures.

8 At this point the Department is seeking

9 comment on the proposed test procedures and the

reference updates, specifically whether these updates

11 to the standards would introduce any additional testing

12 burden or measurement of lamp efficacy.

13 MR. BROOKMAN: So you can see what the

14 Department has wanted to incorporate by reference and

otherwise, and you can see the items that they've

16 wanted to not incorporate as well. So, comments on

17 those, please. Yes.

18 MR. HOWLEY: Joe Howley, making comments on

19 behalf of the NEMA Lamp Technical Section. The

chairman of the technical section could not make it.

21 His flight was canceled, and so I'll be making these on

22 his behalf and the behalf of the NEMA Lamp Technical

23 Committee.

24 Regarding the subject of incorporated

industry standards by reference, NEMA agrees with the

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1 DOE proposal to update the incorporated industry

2 standards by reference to current editions as noted in

3 the NOPR. This is consistent with NEMA's earlier

4 proposal to the DOE, and as further noted by the

Department, such an updating would maintain the desired

6 consistency, accuracy, and in some cases reduce

7 potential errors.

8 NEMA appreciates the update of fluorescent

9 and incandescent lamp test procedures as proposed in

the NOPR and would incorporate all of the most up­to11 date industry standards and practices.

12 However, regarding the subject of IESNA LM9­

13 99, NEMA does not agree from a technical point of view

14 with DOE contention that provisions contained in IESNA

LM9­99 would require the Department to amend the energy

16 conservation standards for fluorescent lamps to take

17 self­absorption provisions of LM9 into account. NEMA

18 will provide more detailed written comments on this

19 subject.

NEMA notes that under substitution method

21 calibration conditions no separately determined self22 absorption factor, or SAF, is required since self23 absorption correction is inherent in the substitution

24 calibration process. An SAF is required when the

measured lamps are different in physical size and shape

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1 from the standard sources used for calibration, not the

2 substitution method.

3 The premise that the addition of the SAF

4 increases measurements by 5 to 10 percent and that it

would therefore be the basis for revised DOE energy

6 efficiency requirements is not correct. We further

7 recommend that since the DOE is not an expert in such

8 matters that the Department involve a photometric

9 measurement expert at NIST, such as Yoshi Ono, since

NIST is responsible for government lamp calibration

11 methods, is a well­respected participant on photometric

12 standard bodies, and is the primary source of luminous

13 flex calibration sources in the U.S.

14 We further note that the Department made use

of the NIST expertise during the development of certain

16 provisions of the 1997 final rule test procedures for

17 lamps and strongly urge DOE to solicit NIST assistance

18 in this particular subject. Thank you.

19 MR. BROOKMAN: Thank you. Thanks very much.

Yes, Gary. Yes, will you hand that down to him?

21 MR. FERNSTROM: Gary Fernstrom, Pacific Gas

22 and Electric Company. Just one quick comment. We see

23 light­emitting diodes coming onto the lighting scene

24 quickly. Is there a provision or thought about test

methods for LEDs or will they fit into some of these

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1 tests?

2 The reason I ask the question is because LEDs

3 will have drivers or the equivalent of ballasts, and

4 I'm not sure whether incandescent test standards or

fluorescent ones or other ones would be the appropriate

6 test standard.

7 MR. BROOKMAN: I'm looking at this side of

8 the room first. Is that appropriate? Ron Lewis.

9 MR. LEWIS: Thanks for the input, but I think

with the schedule that we're under to get this done and

11 to have things definitive, I don't think the time

12 allows for it right now. I agree that as LEDs and

13 solid state lighting becomes more of a factor we're

14 going to have to have test methodologies for that. But

right now, to get this out, I think that we're going to

16 keep it in the spirit existing.

17 MR. FERNSTROM: Okay. So I wasn't suggesting

18 that something new be added, but I was just looking for

19 a clarification as to whether the group felt that

separate test methods would be required or if these

21 would be applicable.

22 MR. BROOKMAN: Michael Scholand.

23 MR. SCHOLAND: Mike Scholand from Navigant

24 Consulting. I can give you ­­ outside of the scope,

first of all, of this rulemaking, this is about

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1 fluorescent lamps and incandescent, as you understand.

2 In Ron's office there is a program to support the

3 development of ­­ increasing the efficiency, the

4 efficacy of light­emitting diodes and to look at

standardization for test methods and representation of

6 efficacies. It's being run by a gentleman by the name

7 of Jim Broderick.

8 He has, under contract, Pacific Northwest

9 National Laboratories and their lighting team, and they

are drafting an IESNA test methodology for testing

11 white light­emitting LED devices. I think that would

12 be the better context for that.

13 MR. FERNSTROM: Okay. So you answered my

14 question. It's not the intention that any of these

test procedures be used for LEDs.

16 MR. SCHOLAND: No, not at all.

17 MR. FERNSTROM: Thank you.

18 MR. BROOKMAN: Thank you. Thanks for the

19 query. Other comments or questions on this segment of

the standards that are anticipated and incorporated by

21 reference or not incorporated by reference?

22 (No response.)

23 MR. BROOKMAN: Okay. Conan.

24 MR. O'ROURKE: Thank you, Doug. The next

section is going to be a discussion of high frequency

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1 fluorescent ballast testing. In the first slide,

2 Department procedures require that they be tested using

3 low frequency. That's been the standard method for

4 testing fluorescent lamps. But the recent addition of

update to ANSI C82.3 does incorporate now a reference

6 ballast for high frequency operation.

7 By continuing to test the fluorescent lamps

8 on low­frequency ballasts when possible, DOE ensures

9 that there is consistent and repeatable efficiency

measurements. ANSI provides only high frequency

11 reference ballast settings for several lamps, so in

12 that case DOE would propose using a high frequency

13 reference ballast for those lamps only.

14 The second slide, referring for high

frequency fluorescent ballast testing. The Department

16 realizes that the market is shifting towards high

17 frequency ballasts which would operate the lamps at

18 high frequency. So future industry trends may provide

19 input in whether they should shift the test procedures

over to high frequency operation measurement

21 capabilities.

22 In such a case, the Department may be willing

23 to amend its procedures by choosing the ratings for

24 either high frequency or low frequency, and then you

could use one to scale the other when the case may be.

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1 So the Department is seeking comment on

2 whether they should limit its testing to low frequency

3 ballasts at this time.

4 MR. BROOKMAN: Joe, do you have a comment?

Joe.

6 MR. HOWLEY: I think NEMA generally agrees

7 but the technical committee will be providing written

8 comments on this.

9 MR. BROOKMAN: Thank you.

MR. O'ROURKE: Thank you. Next we turn it

11 back over to Michael.

12 MR. FERNSTROM: One more comment?

13 MR. SCHOLAND: Sure. Go ahead.

14 MR. FERNSTROM: Gary Fernstrom, PG&E. We

believe that ballast testing should not be limited to

16 low frequency and high frequency should be considered

17 as well.

18 MR. BROOKMAN: Thank you. Any additional

19 comments on that point? I see none.

MR. SCHOLAND: Okay. Mike Scholand here

21 continuing on Slide 15. Thanks, Conan. Let's now

22 discuss the rounding of fluorescent lamp efficacy.

23 Lamp efficacy is defined in the Code of

24 Federal Regulations as the ratio of measured lamp lumen

output in lumens to the measured lamp electrical power

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1 input in watts rounded to the nearest whole number in

2 units of lumens per watt.

3 So for fluorescent lamps, lamp efficacy is

4 rounded off to the nearest lumen per watt. For

incandescent reflector lamps, it's rounded to the

6 nearest tenth of a lumen per watt.

7 The DOE believes that the accuracy of

8 efficacy measurements is crucial in order to maximize

9 energy savings under the Department's regulations. DOE

therefore is proposing to revise the fluorescent lamp

11 test procedure such that all efficacy measurements for

12 fluorescent lamps be rounded to the nearest tenth of a

13 lumen per watt.

14 This proposal is consistent with DOE's

approach in the May '97 final rule regarding the

16 rounding practice required for the calculation of

17 incandescent reflector lamp efficacy. In that rule,

18 DOE stated that IRL lamp efficacy should be rounded to

19 the nearest tenth of a lumen per watt in order to

retain the significant figures in the EPCA standard for

21 IRL.

22 DOE notes that the average lamp efficacy for

23 general service fluorescent lamps, as listed in EPCA,

24 are specified to the nearest tenth of a lumen per watt.

Finally, the proposed revision to the

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1 efficacy rounding practice for general service

2 fluorescent lamps does not alter the method for taking

3 the test measurements but only the calculation of lamp

4 efficacy itself.

DOE seeks comment on whether fluorescent lamp

6 efficacy should be calculated to the nearest tenth of a

7 lumen per watt.

8 MR. BROOKMAN: Joe.

9 MR. HOWLEY: Joe Howley. The lamp

manufacturers have found no issue with rounding to the

11 nearest whole number. Has been the case since 1997.

12 However, they're taking this proposal into

13 consideration and will provide further written

14 comments.

MR. BROOKMAN: Thank you.

16 MR. SCHOLAND: Steve.

17 MR. NADEL: Yes. We support use of tenths.

18 As we use the data, oftentimes the rounding is a

19 judgment call to try to draw a clean standard. I think

the tenths will make it much easier to do.

21 MR. BROOKMAN: Thank you.

22 MR. SCHOLAND: Okay. Thank you. Any other

23 comments on Issue Number 3?

24 (No response.)

MR. SCHOLAND: Okay. Now let's discuss the

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1 measurement and calculation of correlated color

2 temperature. The Department uses correlated color

3 temperature for two purposes. The first one is, DOE

4 uses the metric to define a colored fluorescent lamp

and a colored incandescent lamp, both of which types

6 are excluded from regulation.

7 The second purpose is a kind of proposed

8 purpose which is relating to the energy conservation

9 standard advance notice of proposed rule we'll be

discussing later today. That is, DOE is considering to

11 establish product classes for fluorescent lamps in part

12 around correlated color temperature.

13 So now let's look at correlated color

14 temperature for fluorescent lamps. The existing test

procedures for fluorescent and incandescent lamps in

16 the Code of Federal Regulations do not provide guidance

17 or methodologies for determining or calculating

18 correlated color temperature. DOE therefore proposes

19 to incorporate by reference IESNA LM9­1999 to determine

CCT for fluorescent lamps.

21 DOE does not believe the adoption of this

22 standard imposes excessive burden on manufacturers

23 because they already use this method to calculate

24 chromaticity coordinates to report on the CCT for their

product catalogues and marketing literature.

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1 DOE proposes to amend the definition of

2 colored fluorescent lamp in the notice of proposed

3 rulemaking to include references to IESNA LM9­1999.

4 DOE seeks comment on the proposed

incorporation by reference of the industry standard

6 LM9­1999, the title of which is IESNA Approved Method

7 for the Electrical and Photometric Measurement of

8 Fluorescent Lamps, for measuring and determining CCT

9 for fluorescent lamps.

Joe.

11 MR. HOWLEY: The NEMA agrees that LM9­1999 is

12 appropriate as both a test procedure and as a means to

13 determine fluorescent lamp CCT. Thank you.

14 MR. SCHOLAND: Great.

MR. BROOKMAN: Additional comments?

16 (No response.)

17 MR. SCHOLAND: Okay. Slide 20. The Energy

18 Independence and Security Act of 2007 introduced a new

19 definition to the statute for colored incandescent

lamp. The definition is shown here on the screen, and

21 essentially it says a colored incandescent lamp is in

22 part an incandescent lamp with a correlated color

23 temperature less than 2,500 Kelvin or greater than

24 4,600 Kelvin where the correlated color temperature is

computed according to the Journal of Optical Society of

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1 America, Volume 58, pages 1528 to 1595 (1986). We have

2 noted that that, we think, is a typographical error in

3 the statute, that it should be 1968.

4 EISA 2007 gives a precise reference which DOE

proposes to incorporate into its incandescent test

6 procedure in this notice of proposed rulemaking. DOE

7 does not consider this action to be unduly burdensome

8 as no manufacturer is required to determine the CCT of

9 their incandescent lamps unless they're classifying

them as colored incandescent lamps, at which point they

11 would not be subject to standards.

12 Are there any questions on the CCT for

13 colored incandescent lamps? Okay.

14 MR. BROOKMAN: Joe.

MR. HOWLEY: NEMA will be providing written

16 comments.

17 MR. SCHOLAND: Okay. Thank you, Joe. Now

18 let's discuss the definition of basic model for a

19 general service fluorescent lamp. As mentioned

earlier, in the energy conservation standards ANOPR

21 we'll be discussing later today DOE is considering

22 separate product classes for fluorescent lamps based on

23 correlated color temperature.

24 If a standard were to be set based on CCT

product classes, manufacturers would need to test and

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1 report on a basic model for each of those product

2 classes. A basic model involves identifying a lamp or

3 class of lamps which do not have any differentiating

4 electrical, physical, or functional features that

affect efficacy.

6 In the 1997 final rule, DOE defined basic

7 model for general service fluorescent lamps as

8 including all lamps with essentially identical light

9 output, power input, and luminous efficacy regardless

of their CCT. This last part of the definition would

11 not make sense if DOE chooses to establish product

12 classes based on CCT.

13 Therefore, DOE is proposing in this notice of

14 proposed rulemaking to amend the definition of basic

model for general service fluorescent lamps to require

16 that lamps have similar CCTs.

17 DOE seeks comment on its proposal that all

18 general service fluorescent lamps that are considered

19 to be in the same basic model must have similar

correlated color temperatures.

21 MR. BROOKMAN: Joe.

22 MR. HOWLEY: Yes. With regard to this

23 subject, the definition of basic model of a general

24 service fluorescent lamp such that all general service

fluorescent lamps are considered to be the same basic

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1 model will have similar ­­ okay. Regarding this

2 subject, will have similar correlated color

3 temperatures. NEMA has some concerns with this

4 proposal.

Today the industry uses CCTs as a nominal

6 designation and not as a primary designation of the

7 general service fluorescent color. While NEMA is not

8 opposed to considering the addition of CCT to the

9 definition of general service fluorescent lamp basic

model, a suitable test tolerance factor would need to

11 be developed.

12 Further, NEMA notes specifically that the

13 language proposed by DOE requiring tested CCT to be

14 rounded to the nearest unit, one unit out of several

thousand is not technically meaningful and indicates a

16 false level of precision and reproducibility.

17 NEMA will accordingly comment in more detail

18 on this subject in written form, and including a

19 possible alternative proposal to DOE for consideration.

NEMA does agree with DOE that maintaining

21 determination of color rendering index rounded to the

22 nearest unit is fully appropriate. Thank you.

23 MR. BROOKMAN: I know your technical expert

24 is not here, but are you able to send a signal to the

Department of what kind of alternative you might

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1 suggest?

2 MR. HOWLEY: No, I'm ­­ at this time I'm not

3 able to comment further on that.

4 MR. BROOKMAN: Okay, okay. I thought I'd

try.

6 MR. HOWLEY: Okay.

7 (Laughter.)

8 MR. BROOKMAN: Steve Nadel.

9 MR. NADEL: Yes. I'm trying to understand

what you mean by "similar." If I understand correctly,

11 in the past we've used the same general model whether

12 it's, you know, a 3,000 Kelvin, a 3,500, or a 4,100.

13 Those are all the same basic model. This whole thing

14 is being introduced to get at the call them 5,000

degree Kelvin lamps.

16 Does that mean we're just going to have

17 demarcation between basic models, everything from, you

18 know, under 4,500 up to 29, 28, whatever it is, as one

19 classification and everything else is another? Or, are

you going to suggest that the 3,000 versus 3,500 versus

21 4,100 each be separate basic models, each subject to

22 testing?

23 MR. BROOKMAN: Mike Scholand.

24 MR. SCHOLAND: Mike Scholand from Navigant.

Thanks, Doug, and Steve, for that question. It forces

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1 us to clarify this ambiguous statement. I guess the

2 issue is the old version of the definition of basic

3 model for general service fluorescent lamp required

4 that ­­ basically does not allow you to have different

basic models according to correlated color temperature.

6 We cannot define at this point in our

7 proposal, because DOE is also discussing the

8 possibility in the ANOPR of establishing product

9 classes around correlated color temperature, and it ­­

you know, depending on comment and discussion, it could

11 establish two classes, as was NEMA's proposal on the

12 framework document, or it might establish multiple

13 classes of CCT.

14 DOE cannot prescribe those now, and so rather

than create ranges that don't make sense in this

16 definition, using the term "similar" CCTs lets you go

17 far enough to say that, yes, CCT matters in the

18 definition of basic matter. But in the energy

19 conservation standard you will actually be setting the

product classes. You will be setting a lumen­per­watt

21 requirement for those product classes, however many

22 bins of CCTs that you have. And, manufacturers will

23 have one basic model for each of those.

24 So the ranges of CCT will be established in

the energy conservation standards rulemaking, but in

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1 the test procedure we simply want to modify this term

2 "basic model" to show that CCT matters.

3 Does that answer your question?

4 MR. NADEL: I think it does. If I understood

correctly, you are saying your intent is to draw

6 boundaries based on the final product classes in the

7 product rule.

8 MR. SCHOLAND: Correct. Yes.

9 MR. BROOKMAN: Joe.

MR. HOWLEY: Just one more comment to that

11 effect. To the extent that we end up with regulations

12 that cover higher color temperatures, it's clear that

13 as you get higher and higher in color temperature a

14 different product class would be needed as they have

different efficiencies at higher CCTs. So we would

16 agree that if this was extended to higher ranges there

17 would have to be different classes considered. I

18 realize that's for the ANOPR more than this.

19 MR. SCHOLAND: Thank you, Joe. Again, the

Department does not want to say what those are now. It

21 simply wants to recognize that language saying

22 regardless of CCT in the definition of basic model

23 can't be used if the Department is going to use CCT as

24 a product class differentiator in the standard. That's

what this amendment is trying to do. Okay? Conan.

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1 MR. O'ROURKE: Thank you, Michael. The next

2 section we're going to be discussing, reference ballast

3 settings for added fluorescent lamp coverage.

4 The Department proposes adopting reference

ballast settings for regulated lamps that do not yet

6 have ANSI­approved references in C78.81 (2005) and

7 C78.901 (2005). These additional lamps are often lower

8 wattage lamps that replace lamps that are already part

9 of the ANSI standards. The Department has derived each

of these settings based on those lamps. For example, a

11 four­foot T­8 lamp, reference settings were derived

12 from the 32­watt, four­foot T­8 rapid­start lamp.

13 These additional lamps would require

14 reference ballast settings and include several fourfoot lamps and also two­foot U­shape lamps that have

16 lower wattage that have been introduced to the market.

17 For example, the 28­watt, four­foot T8 medium bi­pin

18 lamp.

19 Lamps which the Department is considering

expanding its fluorescent coverage to in the ANOPR

21 preliminary determination and several of these lamps

22 which it does not currently plan to extend coverage to

23 on this rulemaking, such as the VHO and fluorescent

24 lamps and T5 lamps. The Department proposes setting

these lamps to avoid need of reopening of test

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1 procedures in the future if coverage does get extended

2 to cover these lamps.

3 Looking at the proposed reference ballast

4 settings, the first category is for four­foot medium

bi­pin lamps, and these would be for lamps that are on

6 the market today but aren't listed specifically in the

7 ASNI C78.81. We're proposing the reference ballast

8 settings for T12 and T10 lamps would have a voltage of

9 236 bolts, 0.430 amps, and 439 ohms. For the T8 lamp,

it would be 300 volts, 0.265 amps, and 10 ohms.

11 For the two­foot U­shaped lamp that's not

12 contained in ANSI C78.901, for the T12 it would be the

13 236 volts with 0.430 amps and 439 ohms, and the T8 lamp

14 would be 300 volts, 0.265 amps, and 910 ohms.

For the eight­foot single­in slimline lamps

16 that are not listed in C78.81, for the T12 lamps we

17 would look at 625 volts, 0.425 amps, and 1,280 ohms.

18 The T8 lamps would be 625 volts, 0.260 amps, and 1,960

19 ohms.

For the eight­foot recessed double­contact

21 high­output lamps not listed in ANSI C78.81, for the

22 T12 it would be 400 volts, 0.8 amps, and 415 ohms. For

23 the T8 lamp, we would be using 450 volts, 0.395 amps,

24 and 595 ohms.

Then continuing on for the eight­foot very

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1 high output lamps that wouldn't be listed in the ANSI

2 C78.81 ­­ yeah, Steve?

3 MR. NADEL: Yeah, I think it's easier for us

4 to look at the slides than have you read them.

MR. O'ROURKE: That's fine. I didn't know if

6 it was anything you would have wanted to go over

7 specifically as a point, so I at least wanted to make

8 sure that I covered them.

9 MR. BROOKMAN: It's useful to have a good

portion of this in the record as well.

11 MR. NADEL: Okay.

12 MR. BROOKMAN: Okay. There's a utility in

13 this.

14 MR. O'ROURKE: For the T12 lamp, it would be

400 volts, 1.5 amps, and 215 ohms.

16 Normal and high­output lamps, nominal length

17 of four feet, not listed. For the T5 we're listing 329

18 volts, 0.17 amps, and 950 ohms. For the high­outputs,

19 it would be 235 volts, 0.46 amps, and 255 ohms.

For reference ballast settings for the T5,

21 should the Department extend coverage to the T5s or

22 other lengths other than four­foot nominal, the

23 Department would establish reference ballast settings

24 to derive what these reference ballast settings should

be from the IEC standard. The Department would

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1 determine the appropriate lamp replacements that exist

2 in industry market and use the corresponding reference

3 ballasts or the lamps that fall into that category.

4 So the Department is seeking comments on

proposed reference ballast settings.

6 MR. BROOKMAN: Joe.

7 MR. HOWLEY: A comment from the NEMA

8 Technical Committee on this issue. Regarding the

9 subject of adopting test procedures for lamps that have

not yet been covered or regulated by DOE solely for the

11 purpose of expediting the test procedure NOPR process,

12 NEMA is strongly opposed to this concept, particularly

13 where there is a lack of appropriate consensus industry

14 referenced ballast test settings.

NEMA understands the need to establish

16 reference test circuits for fluorescent lamps covered

17 by the final rule. However, NEMA strongly urges DOE to

18 accept that it is of paramount important to first

19 establish which new lamp types will be covered and to

subsequently then establish technically relevant

21 reference ballast settings and possible other test

22 conditions for those lamp types.

23 There will always be lamp innovations that

24 precede standardization. This is normal and a natural

part of the innovation cycle. NEMA is concerned that

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1 establishing new, generic, mandatory reference ballast

2 settings that must arbitrarily be applied to new,

3 unanticipated lamp types could also prevent the

4 commercialization of otherwise viable new energyefficient lamp designs, especially for lamps that might

6 only be intended for high­frequency, dimming, or

7 controllable operation.

8 Fundamentally, this concept is about the

9 freedom to innovate new general service fluorescent

lamp designs without being constrained by reference

11 circuits that relate to old ballast designs or

12 operating points. NEMA will propose in more detail how

13 such situations can be suitably handled for the

14 regulatory process. Thank you.

MR. BROOKMAN: Any follow­on questions? That

16 was a lot. No? Okay. Ron Lewis.

17 MR. LEWIS: We are in a situation where it's

18 been the tradition ­­ I think it goes back to the

19 process rule time ­­ of trying to have the test

procedures completed about the time that we have the

21 NOPR for the standards done. That's been historically

22 how it's been handled.

23 We also have the situation that once these

24 are put through to a final rule, published, and have an

effective date, then they have to endure for a time

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1 period. So we're trying to be forward­looking without

2 inhibiting creativity or innovation, but also realizing

3 by the time this gets passed and has an effective date

4 and all the rest that our opportunity will be a while

before we can encompass new devices into it.

6 So to the degree that you can look forward

7 and give us input, that's helpful for that. We want

8 sustainability. We want to impact those products even

9 if they may be in the early stages of coming into

practical and commercial use.

11 There are time ingredients here that are

12 against us, so we're trying to reach out and get our

13 arms around some of those things. So to the point that

14 you can give us some direction and input on things that

might be in the works, that would be helpful.

16 MR. HOWLEY: Okay. NEMA will provide some

17 more written comments and ideas that will help in this

18 area. Thanks, Ron.

19 MR. BROOKMAN: Thank you. Steve Nadel.

MR. NADEL: In the spirit that this is a

21 workshop and I'm trying to understand things, I have a

22 question for NEMA. If I understand the DOE proposal,

23 they have some specific values for a whole bunch of

24 classes that they're proposing to cover in the ANOPR

and then they are also proposing settings for two

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1 categories that they are not presently covering in the

2 ANOPR, the VHOs and the T5s.

3 I was wondering; Joe, you mentioned that some

4 of these values are not well determined. I wondered

whether that applies to both categories or whether that

6 really applies more to the T5 category because the VHO

7 has been around for ages.

8 MR. BROOKMAN: Joe.

9 MR. HOWLEY: With regard to new products,

yeah, it would ­­ I think they're looking at products

11 where there's no standards set, which is a different

12 issue than the VHO products, which have been around for

13 quite a while.

14 MR. BROOKMAN: Thank you. Final comments on

this subject?

16 (No response.)

17 MR. SCHOLAND: You can sit down, Conan. I'll

18 take the last view. Thank you very much, Conan.

19 The last two sections I'm going to start by

discussing the test procedures for general service

21 incandescent lamps. As you're all aware, the Energy

22 Independence and Security Act of 2007 established

23 energy conservation standards for general service

24 incandescent lamps, and DOE does have a limited test

procedure in the Code of Federal Regulations today

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1 which is primarily for labeling for the Federal Trade

2 Commission.

3 Therefore, in this NOPR DOE is proposing to

4 amend that test procedure to specify the units to be

tested. That's the first one. Second, to define basic

6 model for general service incandescent lamp. And

7 finally, to provide a method for calculating the GSIL,

8 the general service incandescent lamp, annual energy

9 consumption and efficacy.

Now, because of the similarity in technology

11 between the general service incandescent lamps and

12 incandescent reflector lamps, DOE is proposing that the

13 above additions to the general service incandescent

14 lamp test procedure be implemented in the same manner

as the existing IRL test procedure. So DOE's proposal

16 is basically consistent with what's there for reflector

17 lamps.

18 DOE is seeking comment on this proposed

19 addition to the general service incandescent lamp test

procedure. Any comments?

21 MR. BROOKMAN: Joe.

22 MR. HOWLEY: Yes. Regarding the subject of

23 testing for general service incandescent lamps, NEMA

24 basically agrees with the DOE plan to insert language

for test procedures in a manner that would be

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1 consistent with the IRL procedures.

2 However, NEMA will strongly suggest in its

3 written comments that to mitigate the additional

4 burdens presented to industry by an additional new set

of 12 months' reporting provisions, the DOE should do

6 away with the existing antiquated pre­production

7 notification requirement for all covered lamp types.

8 NEMA does not believe the pre­production notification

9 has proven useful to the Department or adds value to

the public.

11 This provision requires the assignment of

12 industry resources to undertake a superfluous activity

13 since the post­12 month production provision ensures

14 that production lamps are complying with the minimum

efficiency requirements.

16 In addition, NEMA is aware the Department and

17 its contractors are in the process of developing a

18 modern electronic compliance database that will not

19 easily lend itself to automating the old pre­production

notification. NEMA contends that the public interest

21 would not be jeopardized by this simplification while

22 it would eliminate a non­useful burden on industry.

23 NEMA contends that the elimination of the

24 pre­production requirements would be in keeping with

federal guidelines aimed at minimizing burdensome

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1 requirements. If DOE desires the industry maintain

2 evidence of compliance before launching a new product,

3 such a variation of this provision would be acceptable

4 as it would still put industry in the position of

needing to demonstrate initial minimum efficacy

6 compliance upon request before production commenced.

7 Lastly, it is not clear to NEMA how DOE will

8 implement the reporting aspects of its new lamp rules

9 in a non­burdensome manner. This is a matter of

primary importance to the industry since it involves

11 real resources, cost, and time. It is NEMA's

12 contention that existing basic models that will

13 continue to meet new minimum efficiency standards that

14 might be adopted under the federal rule for the

companion ANOPR should not have to be retested by

16 industry or re­reported unless industry wishes to do so

17 in a voluntary manner.

18 In addition, to further promote non19 burdensome reporting requirements, NEMA strongly

encourages DOE to ensure that its electronic compliance

21 submission system is fully operational prior to the

22 need for industry to submit any reporting data that

23 would be necessary under new provisions of the ANOPR.

24 NEMA also reiterates its request discussed

previously to eliminate the pre­launch reporting

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1 requirements that are contained in the current

2 reporting requirements. Instead manufacturers should

3 be required to maintain proof of compliance prior to

4 the production for sale and then to follow up after 12

months of electronically reported test data.

6 NEMA urges DOE to ensure that as part of its

7 transition to new lamp requirements that it would be

8 advisable for the Department to implement an easy­to9 understand Web­based educational resource that will

explain to all NEMA manufacturers, in particular non11 NEMA manufacturers (sic) or importers, how to ensure

12 compliance. Thank you.

13 MR. BROOKMAN: Thank you. Other comments

14 related to this section?

(No response.)

16 MR. SCHOLAND: Okay.

17 MR. BROOKMAN: Okay.

18 MR. SCHOLAND: Hearing none, the final

19 section of the test procedure is the off mode and

standby mode ­­ excuse me. Go ahead.

21 MR. FERNSTROM: If we could ­­

22 MR. BROOKMAN: Gary, please.

23 MR. FERNSTROM: ­­ go back to No. 7 just

24 briefly. This is Gary Fernstrom from Pacific Gas and

Electric Company. We would encourage DOE to define the

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1 basic model general service incandescent lamp broadly

2 so that a full range of correlated color temperatures

3 are included. That is to say so that higher color

4 temperature incandescent lamps are included and not

excluded.

6 MR. SCHOLAND: Okay. Gary, I don't know if

7 you're aware. The greater than 4,600 Kelvin is

8 considered colored incandescent and less than ­­ is it

9 2,600 I believe ­­ is colored. So within that band it

includes incandescent, halogen, and halogen infrared

11 technologies.

12 MR. FERNSTROM: That's precisely the point

13 that I'm getting at. We would encourage DOE to

14 consider a broader range because we're concerned that

lamps just above the upper limit would not be tested or

16 regulated in any way.

17 MR. SCHOLAND: Okay.

18 MR. BROOKMAN: Any other comments on this

19 point?

MR. SCHOLAND: I just would like to go back

21 to Slide 20 for Gary's information. EISA 2007

22 introduced a definition for colored incandescent lamp.

23 This is part of the statute which says correlated

24 color temperature less than 2,500 Kelvin or greater

than 4,600 Kelvin where correlated color temperature is

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1 computed according to the journal methodology.

2 DOE would not be able to include correlated

3 color temperatures outside of this range, Gary, without

4 a statutory amendment.

MR. FERNSTROM: Okay. Thanks for the

6 clarification. The general concern that we have, not

7 withstanding the regulatory mandate here, is that

8 loopholes will be found and products will be developed

9 just outside the limits and therefore will continue to

be non­regulated.

11 MR. BROOKMAN: Thanks for that clarification.

12 MR. SCHOLAND: Thank you. Okay. Back to

13 Slide 31, the off mode and standby mode.

14 In Section 310.3 of EISA 2007, Congress

directed the Department to amend its test procedures to

16 incorporate a measure of off mode and standby mode

17 energy consumption if feasible. DOE believes that for

18 general service fluorescent lamps, incandescent

19 reflector lamps, and general service incandescent

lamps, none of these lamp types employ a standby mode

21 or off mode.

22 If the lamp must be disconnected from the

23 main power source in order for it to provide no active

24 mode function ­­ that is, emitting light ­­ and if the

light is disconnected from the main power source, the

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1 lamp does not satisfy the requirement of operating in

2 standby mode or off mode. This is according to the

3 statutory definitions of these three different modes:

4 active mode, standby mode, and off mode.

DOE therefore believes that all covered

6 products that meet the definitions of general service

7 fluorescent lamps, incandescent reflector lamps, and

8 general service incandescent lamps are single­function

9 products and do not offer any secondary user­oriented

or protective functions.

11 DOE seeks comment on its proposal to not

12 incorporate a measure of off mode and standby mode

13 energy consumption in its test procedures for these

14 three lamp types. Discussion, please.

MR. BROOKMAN: Joe.

16 MR. HOWLEY: Yes. Regarding the subject of

17 off mode and standby mode energy consumption, NEMA

18 agrees with DOE conclusions that provisions do not

19 technically apply to the covered lamps and accordingly

there is no need to expand the lamp test procedure to

21 incorporate measurements for either off mode or standby

22 mode. Thank you.

23 MR. BROOKMAN: Additional comments? Gary.

24 MR. FERNSTROM: Hi. Gary Fernstrom, Pacific

Gas and Electric Company. We're beginning to see some

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1 compact fluorescent lamps that contain integral control

2 in them so that they can be turned on and off either

3 through a power line carrier or wirelessly. So the

4 question is, how would these lamps be dealt with? They

would presumably be outside of the scope of this

6 regulation.

7 MR. SCHOLAND: That is correct, Gary.

8 Compact fluorescent lamps are outside of the scope of

9 this test procedure.

MR. FERNSTROM: Means that it's an

11 incandescent test procedure.

12 MR. SCHOLAND: Well, the test procedure is

13 addressing general service fluorescent lamps,

14 incandescent reflector lamps, and general service

incandescent lamps. So compact fluorescent lamp are

16 another category that's just beyond the scope of ­­

17 sorry.

18 MR. FERNSTROM: Thank you.

19 MR. SCHOLAND: Thank you for the comment.

Other comments on this issue?

21 (No response)

22 MR. SCHOLAND: So the last slide here is how

23 to submit comments. This is also ­­ you will see it in

24 the notice of proposed rulemaking when it's published

on Thursday of this week, on the 13th. This also gives

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1 you the e­mail address, how to submit written comments,

2 courier comments.

3 The comment period. Again, it's 75 days

4 after the date of publication in the Federal Register,

and I believe it's around May 28th or 29th. Don't

6 quote me on that, but you'll see it in the notice and

7 Linda will be sending an e­mail to all the stakeholders

8 on the distribution list once the notices are

9 published. So you will get the actual date in that email.

11 Any other comments or questions or discussion

12 points on test procedure?

13 (No response.)

14 MR. SCHOLAND: No? Great.

MR. BROOKMAN: So we have a choice to make.

16 We're scheduled ­­ at this point on the agenda we are

17 allowed to take a break. However, we've only been at

18 this for a little more than an hour, so we can keep

19 plugging ahead if you wish, also. What's your

preference? Let's keep going.

21 Okay. So then we're moving on to Energy

22 Conservation Standard Overview.

23 MR. SCHOLAND: Mimi?

24 MR. BROOKMAN: And then in about, maybe, a

half an hour or so we will take a break and get a cup

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1 of coffee and the like.

2 Energy Conservation Standard Overview

3 Mahima Gupta

4 (PowerPoint presentation.)

MS. GUPTA: Hi. My name is Mimi Gupta. I'm

6 going to be starting off our discussion on the energy

7 conservation standards for general service fluorescent

8 lamps and incandescent reflector lamps ANOPR. Today

9 I'd just like to give you a brief overview of the

rulemaking and what we'll be talking about in the

11 upcoming day or days.

12 The purpose of this public meeting is to

13 present the methodologies and characterize the results

14 for the analyses completed to date, to discuss specific

issues related to each analysis, to seek input from

16 attendees on methodologies, assumptions, and on data

17 sources, and to describe some of the upcoming analyses

18 and next steps.

19 The Energy Policy and Conservation Act, or

EPCA, directs DOE to consider seven factors when

21 setting energy conservation standards, and this slide

22 shows the seven factors and the corresponding analyses

23 done in the rulemaking that address those seven

24 factors.

This slide shows the different analyses, part

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1 of the ANOPR, advance notice of proposed rulemaking,

2 that we'll be discussing in the upcoming presentations.

3 The Department has completed a market and technology

4 assessment and a screening analysis, which feed into

the engineering analysis. The engineering analysis, in

6 conjunction with the product price determination and

7 energy use characterization, serve as inputs into the

8 life­cycle cost analysis and national impact analysis.

9 In addition to discussing these ANOPR

analyses, we'll also be discussing today the DOE's

11 preliminary determination on expanding its scope of

12 coverage to additional general service fluorescent

13 lamps.

14 After a period of comment after the ANOPR,

the next step in the rulemaking process is the notice

16 of proposed rulemaking, or NOPR. This slide shows the

17 different analyses done in the NOPR. First, the ANOPR

18 analyses are revised. Trial standard levels are

19 established. The Department conducts an LCC subgroup

analysis, a manufacturer utility and employment impact

21 analysis, an environmental assessment, and a regulatory

22 impact analysis.

23 Throughout the presentations you'll see that

24 we highlight several issues for comment. These issues

for comment are in a handout in your packet. Several

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1 issues for comment have issue numbers beside them which

2 correspond to the last section of the ANOPR, the issues

3 that we highlight in the ANOPR notice. Some issues

4 don't have issue numbers on them, but we welcome

comments on all issues we raise as well as any other

6 issues stakeholders would like to talk about.

7 Finally, I'd just like to say that

8 participants are invited to provide summary comments or

9 statements and they're invited to raise any additional

issues for discussion today, and that the ANOPR comment

11 period will be closing 30 days after publication in the

12 Federal Register. As Mike said, the ANOPR is scheduled

13 to be published on March 13th, and so that would mean

14 the comment period would close on April 12th, 2008.

I think we're opening it up for any opening

16 statements. Right, Doug?

17 MR. BROOKMAN: Yes. So, as reflected in the

18 agenda, any summary comments, overview comments at this

19 time would be welcome. Andrew Delaski.

Comments from Participants Regarding the Energy

21 Conservation Standard ANOPR

22 MR. DELASKI: Sure. First of all, I

23 apologize for being late this morning. Delta has some

24 liability problems with their planes this morning. So

I'm glad to be here. I want to make just a couple of

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1 comments as to ­­ to respond to the Department's

2 publication of the ANOPR before the rulemaking.

3 One is, I want to just take a moment to

4 provide a little bit of context. I was struck last

week with the President at the Renewal Energy

6 Conference of Washington last week. There was an issue

7 of a fact sheet by the White House, and that fact sheet

8 gave prominent mention to appliance standards in the

9 fact sheet. I think the context of this rulemaking is

incredibly important.

11 In the fact sheet, which is entitled

12 "Increasing Our Energy Security and Confronting Climate

13 Change" issued by the White House last Wednesday ­­

14 I'll just quote from it ­­ "In December President Bush

signed the Energy Independence and Security Act of

16 2007, which responded to his 20 In 10 challenge in last

17 year's State of the Union Address to improve

18 efficiency." It mentions fuel economy standards, it

19 mentions renewables, and then it goes on to about

appliance standards.

21 "The lighting efficiency mandate will improve

22 lighting efficiency by more than 70 percent by 2020."

23 We were just talking about the tests for general

24 service lamps. I think it's worth taking a second to

mention the leadership of Chairman Bingaman, Bingle,

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1 Baucher, Markey, and Congresswoman Harmon in

2 accomplishing the general service lamp standard that

3 was enacted in EISA but also to acknowledge the

4 leadership of the industry: General Electric, of

Sylvania, of Philips, and putting the lighting

6 standards effectively on the table. It was an enormous

7 step forward made possible through the leadership of

8 Philips, GE, and Sylvania, as well as the members of

9 Congress that made that standard happen.

Also, the fact sheet goes on to talk about ­­

11 it says, "The appliance efficiency mandate sets over 45

12 new standards for appliances." Now, I'm not quite sure

13 how the math got worked out there. I count 10.

14 (Laughter.)

MR. DELASKI: But I suppose if you count all

16 the additional requirements for future rulemakings that

17 are embedded in EISA that it might very well count out

18 to 45.

19 So I think that's just an important context

to have the White House come out with a fact sheet.

21 It's a big pat on the back, I think, for the

22 Department, acknowledgment of the work that's going on

23 at the Department to set efficiency standards and to

24 advance them as one of the cornerstones of how this

administration views how energy efficiency fits into an

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1 overall energy policy.

2 I want to congratulate DOE on this particular

3 rulemaking because I know it must have been a big lift

4 to go from having a rulemaking which covered three

product categories, broadly speaking. To take out the

6 general service lamps must have been ­­ as I read

7 through the ANOPR and the technical support documents,

8 I just thought, my gosh, where did all the general

9 service lamp stuff go.

So it must have been a big technical lift to

11 get all that out of there, so congratulations for

12 accomplishing that. What I expect and hope is we will

13 be able to keep on your schedule for a final rule

14 according to the published schedule, which I think will

be a challenge still.

16 This rulemaking, and my last point I want to

17 make, is a critically important rulemaking in the scope

18 of the overall set of things the Department is now

19 tackling, the 30­odd rulemakings. I think Ron told me

35 at one point. There are huge savings at stake in

21 this particular rulemaking.

22 On the ANOPR analysis published by DOE, if

23 you look at the levels that are the max ­­ that meet

24 the legal criteria of maximum level of cost effective

savings, for general service fluorescent lamps the

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1 current analysis shows a potential savings of 16 quads

2 at a net present value of $54 billion using the 3

3 percent discount rate. For the incandescent reflector

4 lamps, 2.4 quads and $15 billion NPV.

So these two together are approaching 20

6 quads of potential energy savings that are cost

7 effective based on the analysis published by DOE at a

8 net present value of $70 billion. It's a big

9 rulemaking.

To put that in a little bit of context, I

11 think many people in this room are familiar with the

12 CR17 rulemaking for air conditioners, which was at the

13 time one of the most important rulemakings the

14 Department ever completed. The total savings from that

rulemaking estimated by DOE was 4.2 quads. The NPV was

16 a billion bucks. We're talking about energy savings

17 that are on the order of four to five times greater

18 than the CR13 rule with a net present value on the

19 order of 70 times greater according to the Department's

analysis published.

21 So it's an extraordinarily important

22 rulemaking. There's a lot of analysis ahead of us, a

23 lot of discussion ahead of us. I think the Department

24 has done a very effective job and a very thorough

analysis. We will of course have some points that we

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1 want to discuss and comment on, but I think it really

2 has laid the groundwork for what could be an enormously

3 important rulemaking by the Department. So, thank you.

4 MR. BROOKMAN: Thank you, Andrew. Additional

overview comments at this time, summary comments?

6 (No response.)

7 MR. BROOKMAN: I see no more. Okay. Mimi.

8 MS. GUPTA: Okay. So I think Mike Scholand

9 will be talking about the Scope of Coverage section of

the ANOPR.

11 MR. BROOKMAN: Ron Lewis, please.

12 MR. LEWIS: While Michael is getting ready,

13 the word "lift" has a significant meaning on this in

14 that this ANOPR was almost completely done, written,

including the incandescent lamps, general service

16 incandescent lamps, and we had to lift it out, extract

17 it, and redo the analysis. This team has done an

18 incredible job of trying to handle in stride the change

19 in the legislation, which outwardly could appear like

it reduced our effort, but because we were so far along

21 with things, trying to then go back and rewrite it and

22 take into stride the EISA 2007 legislation.

23 Before you came in this morning, and I was a

24 little bit short with it, we wanted to leave time.

There was a lot of confusion in our minds as we were

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1 trying to integrate a whole lot of things and get this

2 done right. We wanted to leave room for everybody and

3 get all the comment and make sure we clarified

4 everything that we possibly could because there was so

much confusion around this.

6 So we had left two days to handle all this.

7 We're ahead of schedule, which is great, but I wanted

8 to make sure everybody had the chance to give their

9 comment. Because of the confusion that we experienced

with trying to redo everything and look at definitions

11 and all kinds of things that changed, that we didn't

12 rush through it, that we handled it as comprehensively

13 as possible.

14 So we thank you for your input, and that word

"lift" meant a little bit different to us, as "extract

16 and redo."

17 MR. BROOKMAN: I also thought the "lift"

18 meant quantity. Quantity, yes. Okay. Michael

19 Scholand.

Scope of Coverage

21 Michael Scholand

22 (PowerPoint presentation.)

23 MR. SCHOLAND: Thank you, Doug. Mike

24 Scholand here from Navigant Consulting. I'm going to

talk us through now the Scope of Coverage section of

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1 the advance notice of proposed rulemaking. This

2 section addresses the scope of coverage for additional

3 general service fluorescent lamps.

4 As we had discussed earlier, the Energy

Independence and Security Act changed the scope of

6 coverage in this rulemaking. First and foremost, it

7 established energy conservation standards for general

8 service incandescent lamps. Therefore, those lamps are

9 no longer part of the standards rulemaking.

It amended Section 42 U.S. Code 6295(I)(5) to

11 remove the Department's authority to consider coverage

12 of additional general service incandescent lamps. So

13 in the framework document DOE had contemplated looking

14 at both additional general service fluorescent lamps

and additional general service incandescent lamps.

16 Following EISA, the incandescent portion of that was

17 removed. Incandescent reflector lamps are part of the

18 definition of general service incandescent lamps,

19 therefore no additional incandescent reflector lamps

are considered in this scope of coverage for this

21 rulemaking.

22 Next, it modified the EPCA definitions for

23 general service fluorescent lamps and incandescent

24 reflector lamps, bringing additional lamps under DOE's

authority, which were then added to the scope of the

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1 rule.

2 So, any questions or comments on that?

3 Steve, you have a puzzled look on your face.

4 MR. BROOKMAN: Steve Nadel.

MR. NADEL: Yeah. I have to go back to the

6 wording of the EISA language, but as someone who was

7 intimately involved in this, I don't recall any

8 discussion about removing DOE's authority to consider

9 other product classes. It may have removed the

obligation to say DOE must do it, but I don't believe,

11 and I need to check back the legal language, that it

12 removed the authority for DOE to be able to change

13 coverage.

14 MR. BROOKMAN: Pam.

MS. HORNER: Pam Horner with Osram Sylvania.

16 Just one note, that whenever I speak for the remainder

17 of this it will be on behalf of the NEMA Lamp Section.

18 So when I say NEMA, I mean the Lamp Section.

19 Just a point of clarification, please,

because it will affect a comment I have to make later.

21 Does what you just said, Michael, mean that PAR 20

22 lamps are not covered under this ANOPR?

23 MR. SCHOLAND: PAR 20 lamps are not covered?

24 I believe they are covered. I think they're ­­

MS. HORNER: You said additional coverage,

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1 and so my question is, EISA specifically brought in

2 smaller ­­ I think this is where Steve was headed ­­

3 smaller diameter lamps.

4 MR. SCHOLAND: Correct.

MS. HORNER: Including the PAR 20 type.

6 MR. SCHOLAND: Yes.

7 MS. HORNER: So it will simply affect our

8 comments, so I would like some clarification as to

9 whether you think these are or are not covered by the

candidate standard lamps.

11 MR. SCHOLAND: I do have a slide on this,

12 Pam, coming up, and they are covered because the

13 modifications made by EISA, which is my third bullet on

14 this slide, EPCA modified the definitions of GSFL and

IRL. One of those modifications was to change the

16 lower threshold diameter from two and three­quarters

17 inch to two and one­quarter inch, which is essentially

18 an R18.

19 MS. HORNER: Thank you.

MR. SCHOLAND: So an R20 or a PAR 20 would be

21 covered now, but not by action of the Department.

22 That's what I was ­­ this scope of coverage that I'm

23 discussing here is in the context of DOE, although the

24 first set of slides I'm going to talk about are EISA

impacts.

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1 Do we have another question?

2 MR. BROOKMAN: Yes. Please say your name for

3 the record.

4 MR. WALITSKY: Paul Walitsky, Industrial

Ecology. So, under that definition, a PAR 16 lamp

6 would not be covered, then?

7 MR. SCHOLAND: Correct. The PAR 16 is not

8 covered.

9 MR. BROOKMAN: Thank you.

MR. SCHOLAND: Okay. So now let's discuss

11 the EISA 2007 change to the definition of general

12 service fluorescent lamp. Here you can see the

13 definition of general service fluorescent lamp is on

14 the screen, Slide Number 3. You'll notice in bold

VIII, lamps with a color rendering index greater than

16 or equal to 87. Prior to passage of the legislation

17 that had said 82.

18 So a change was made to the statutory

19 definition of general service fluorescent lamp, which

is part of the scope, that DOE is looked at additional

21 fluorescent lamps, and it raised the CRI from 82 to 87,

22 which brought many more lamps into the Department's

23 purview of consideration for this scope.

24 Okay. And, how did the definition change the

scope of coverage for incandescent reflector lamps,

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1 which we were just getting to. Thanks, Pam.

2 Slide 4. In bold here you will see the

3 changes. Basically, the coverage now includes ER,

4 which is ellipsoidal reflector, BR, for bulge

reflector, and BPAR, for blown parabolic aluminized

6 reflector, or similar bulb shapes. So that provision

7 was added.

8 And then, finally, the diameter provision we

9 were just discussing, diameters exceeding two and a

quarter inches. That previously two and three11 quarters.

12 So what this in essence means is that

13 previously ER and BR shapes were excluded. Now they

14 are included in the definition. And then the diameter

has been made to a smaller size.

16 There are some specific exclusions here which

17 I mention in the bottom bullet. Basically, EISA

18 included exemptions for ER30, BR30, BR40, and ER40

19 lamps rated at 50 watts and less, and it also excluded

BR30, BR40, and ER40 lamps rated at 65 watts. And it

21 excluded R20 lamps rated at 45 watts or less. Those

22 are statutory exclusions and they were introduced by

23 the Energy Independence and Security Act of 2007.

24 Okay. Next slide. Any questions on this

before I move on? Does that clarify it?

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1 (No response.)

2 MR. SCHOLAND: Okay. Now I'll discuss how

3 EISA modified the definition of colored incandescent

4 lamp. EISA introduced a new definition for colored

incandescent lamps as follows. Colored incandescent

6 lamp means an incandescent lamp designated and marketed

7 as a colored lamp that has

8 1) A color rendering index of less than 50,

9 as determined according to the test method given in the

CIE Publication 13.3 (1995), or

11 2) A CCT, a correlated color temperature, of

12 less than 2,500 Kelvin or greater than 4,600 Kelvin

13 where the CCT is computed according to the Journal of

14 Optical Society of America article. The citation here

says 1968, but again in the provision ­­ in the

16 statutory language it's 1986 and we believe that is a

17 typographical error.

18 So essentially, the new definition of colored

19 incandescent lamp removes the exclusion of neodymium

incandescent reflector lamps from regulation. DOE

21 therefore considers standards for these lamps by

22 creating a separate product class for modified spectrum

23 incandescent reflector lamps.

24 Okay. So this is the last slide. This

summarizes all the changes that EISA imposed on the

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1 scope of coverage of product that we were considering

2 in the advance notice of proposed rulemaking. Are

3 there any questions on these slides on EISA impacts?

4 Okay.

MR. BROOKMAN: Yes. Steve Nadel. The new

6 definition effectively removes the exclusion of the

7 "neo­deo­nium."

8 MR. SCHOLAND: Neodymium.

9 MR. BROOKMAN: Thank you. Steve Nadel.

MR. NADEL: Right. You've mentioned a couple

11 of times that you consider the reference to this

12 Journal of Optical Society article a mistake.

13 MR. SCHOLAND: Yes.

14 MR. NADEL: I would encourage the Department

to let the congressional committees know what you

16 believe to be the mistake because I know they're

17 working on a technical correction package now.

18 MR. BROOKMAN: Thank you.

19 MR. SCHOLAND: Ron is making a note. Let the

record show.

21 (Laughter.)

22 MR. BROOKMAN: Okay.

23 MR. SCHOLAND: Okay. So, Slide 6, Expansion

24 of Scope of Coverage. We have an extraction here of

Paragraph 6295(I)(5), where it reads, "The Secretary

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1 shall initiate a rulemaking procedure to determine if

2 the standards in effect for fluorescent lamps should be

3 amended so that they would be applicable to additional

4 general service fluorescent lamps."

A question was raised earlier about the

6 modification to this paragraph. This used to say "and

7 general service incandescent lamps," but following EISA

8 that provision was removed. So DOE is now working

9 under this revised expansion of scope of coverage,

considering additional general service fluorescent

11 lamps, and we have the schedule in a table here on the

12 slide just to show you that at this stage of the

13 advance notice of proposed rulemaking DOE is providing

14 its preliminary determination of scope.

Based on the comments and feedback it gets

16 today and in written comments, DOE will propose a

17 determination of scope in conjunction with the notice

18 of proposed rulemaking. And then based on comments it

19 gets at that point in the rulemaking process, it will

take those back and consider and then issue a final

21 determination of scope at the final rule stage.

22 So, okay. So, what are the criteria that DOE

23 is using when selecting fluorescent lamps for coverage.

24 DOE considered four main criteria, outlined here and

discussed in more detail in the ANOPR, which is

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1 published. The first, obviously, the statutory

2 definition of general service fluorescent lamps.

3 Second is the potential energy savings of those lamps.

4 Third, lamps whose shipments may not be high volume

but have the potential to grow, such as they may become

6 a substitute for regulated lamps, and then finally,

7 potential for a standard to meet two remaining

8 statutory criteria, which are technologically feasible

9 and economically justified.

So, are there any questions on the scope of

11 coverage criteria the Department used?

12 (No response.)

13 MR. SCHOLAND: Okay. On the next slide we

14 show the additional general service fluorescent lamps

in DOE's preliminary determination of scope. There's

16 three lamps identified here: four­foot ­­ these are

17 additional general service fluorescent lamps DOE is

18 preliminarily determining to include in its scope of

19 coverage and therefore regulation. Four­foot medium

bi­pin lamps with wattages greater than or equal to 25

21 watts and less than 28 watts. Right now that threshold

22 cuts off at 28 watts, so this would bring into

23 inclusion wattages of 25. It would be the lower

24 threshold.

For the eight­foot recessed double­contact,

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1 rapid­start, high­output lamps, ones that are not

2 defined in ANSI C78.1 (1991). An example of this would

3 be an 86­watt T8 high­output lamp with a 400 milliamp

4 and high frequency operation.

And then the third group is eight­foot,

6 single­pin, instant start, rapid ­­ excuse me. Eight7 foot, single­pin, instant start, slimline lamps with a

8 rated wattage greater than or equal to 52 watts that

9 are not defined in ANSI C78.3 (1991). An example here

would be a 59­watt T8 single­pin lamp.

11 In the next slide there's a visual

12 representation of how these lamps fit into DOE's scope

13 of coverage. The yellow boxes on this slide represent

14 the lamps that DOE has already covered and is

regulating. The purple boxes represent the additional

16 general service fluorescent lamps that are proposed for

17 coverage.

18 Okay. Finally, on the next slide I briefly

19 discuss the fluorescent lamps DOE considered but is not

presently planning to cover. These lamps are T5

21 miniature bi­pin lamps. The reason DOE has ­­ DOE

22 discusses, again, in more detail in the ANOPR its

23 rationale behind not proposing to cover these lamps at

24 this time. I just summarize them here.

For T5 miniature bi­pin, basically there is a

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1 lower potential for per­unit energy savings because

2 these lamp types already represent a more efficacious

3 product. Second, they represent a small market share.

4 Thirdly, regulation of these lamps may slow adoption

of these higher efficacy products.

6 For the very high output, the VHO lamps,

7 although there may be potential for relatively large

8 per­unit energy savings, research indicates they have a

9 small and decreasing market share.

Finally, for fluorescent lamps with alternate

11 lengths, diameters, base types, and shapes, DOE

12 believes that these other lamps constitute a small

13 market share with little potential to grow.

14 In Slide 11, DOE invites comment on its

consideration of expansion of scope of coverage for

16 general service fluorescent lamps.

17 MR. BROOKMAN: Pam.

18 MS. HORNER: Pam Horner, speaking on behalf

19 of the NEMA Lamp Section. Regarding products to be

covered by DOE, as we noted in the previous discussion,

21 the testing procedure NOPR does reference some

22 suggestions for test procedures for T5 lamps.

23 NEMA is considering support that DOE cover T5

24 lamps. We have not yet achieved a consensus on this,

and it will be in our written comments. But it would

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1 be for those specifically used for general

2 illumination, and we would like to tell you why we are

3 considering this amongst ourselves right now.

4 It is, in particular, to prevent the

introduction of less efficient T5 lamps, namely those

6 that contain halophosphor, into the U.S. market. We

7 would oppose any kind of standards for T5 lamps that

8 would remove any of the existing high efficiency or

9 high efficacy T5 lamps.

Additionally, in summary, we do agree with

11 the DOE on the following coverage points. The 25­watt,

12 four­foot, medium bi­pin lamps, T8 and T12s, are

13 suitable candidates to consider for coverage. T8

14 eight­foot RDC HO lamps should be considered for

coverage. The eight­foot, single­pin, slimline lamps

16 greater than 52 watts should be covered and its

17 corollary, the T8 eight­foot, single­pin, slimline

18 lamps less than 52 watts shouldn't be.

19 MR. BROOKMAN: Should not be?

MS. HORNER: Right. It was implicit. VHO

21 lamps should not be covered. We are in agreement with

22 you. We are also in agreement that lamps with

23 alternate lengths, diameters, bases, or shapes, or a

24 combination thereof, should not be covered except

perhaps in the exception I noted that we are

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1 considering regarding T5s per our comment.

2 We do want to make one point, that when the

3 original analysis was done for fluorescent lamps DOE

4 suggested that it does not need to expand coverage of

two­foot, medium, bi­pin, U­shape lamps with wattages

6 less than 28 watts and that was because there weren't

7 any. Now there are.

8 MR. SCHOLAND: All right.

9 MS. HORNER: So we would like to suggest that

that is a suitable candidate to bring under. In other

11 words, the 25­watt U­bend corresponding lamp. Thank

12 you.

13 MR. BROOKMAN: Thank you. Additional

14 comments on scope of coverage issues? Steve Nadel.

MR. NADEL: Yeah, let me say, we are still

16 looking at all of these things. I would say we

17 generally tend to agree with what NEMA said. We were

18 also looking at the U­bend and wondering whether 25

19 made sense. We are still looking at the 52 watt limit

for the eight­foot. If I understand, there are some 50

21 and 51 watt products. We haven't had a chance to look

22 at them yet and whether they are niche and couldn't be

23 used.

24 We also were interested in covering the T5

for the reason that Pam said, although we would take it

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1 a step farther and say that DOE should analyze

2 opportunities for T5. We are not in any way suggesting

3 at this point we want standards to be set, but we would

4 like to see an analysis, you know, to see are there

opportunities. We recognize that the existing T5

6 products are relatively efficient.

7 The one other comment I would make, and

8 perhaps I should know this, is if it's medium ­­ under

9 your standard, if it's a medium bi­pin base, regardless

of whether it's T8, T5, T10, T­whatever, it is covered,

11 right?

12 MR. SCHOLAND: The way the Department is

13 proposing product classes in this notice, medium bi­pin

14 would all be grouped, but T5 is not medium bi­pin. T5

is miniature.

16 MR. NADEL: Right. That's the point I was

17 making. I know there had at various points been a T10

18 lamp. I just wanted to make sure they would be covered

19 and that they do not provide a potential loophole.

MR. SCHOLAND: In the four­foot length ­­

21 MR. NADEL: Yes.

22 MR. SCHOLAND: ­­ medium bi­pin T10s are

23 included.

24 MR. BROOKMAN: Thank you. Additional

comments on scope of coverage?

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1 (No response.)

2 MR. BROOKMAN: Okay. The next segment on the

3 agenda is fairly extensive and lengthy. It's almost 11

4 o'clock. I'm going to suggest we take a break now.

It's five 'til. I'd like to resume at 10 minutes

6 after. So, 11:10 we'll resume. Please wear your

7 badges while you're in the building.

8 (Brief recess.)

9 MR. BROOKMAN: Okay. Thank you for coming

back so we can resume on time. We left off with the

11 engineering analysis and Mimi.

12 Engineering Analysis

13 Mahima Gupta and Conan O'Rourke

14 (PowerPoint presentation.)

MS. GUPTA: All right. So I'll be starting

16 off our discussion on the analyses for the ANOPR by

17 talking about the market and technology assessment, the

18 screening analysis, the engineering analysis, and the

19 product price determination. These four analyses serve

as foundational analyses for the life­cycle cost

21 analysis and national impact analysis, which we'll be

22 discussing further on in the day and maybe tomorrow.

23 More detail on these analyses can be found in the ANOPR

24 Technical Support Document in Chapters 3 through 6.

So in the market and technology assessment,

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1 DOE characterizes the fluorescent and incandescent

2 reflector lamp market and industry, it identifies

3 several measures to improve efficacy, called technology

4 options, and it establishes product classes for general

service fluorescent lamps and incandescent reflector

6 lamps.

7 The screening analysis then takes the

8 technology options developed in the market and

9 technology assessment and screens several of them out

based on four EPCA criteria, and the resulting

11 technology options are then called design options.

12 The design options are fed into the

13 engineering analysis, where DOE identifies baseline

14 lamps or lamp and ballast systems and their higher

efficacy alternatives. In the product price

16 determination, DOE establishes end user prices for the

17 lamps and ballasts identified in the engineering

18 analysis.

19 So, as I just said, one of the major outputs

of the market and technology assessment is product

21 classes. I'm going to start off by talking about

22 general service fluorescent lamp product classes, and

23 then I'll go on to talk more about incandescent

24 reflector lamp product classes.

EPCA established standards for eight

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1 different categories of fluorescent lamps by lamp type

2 ­­ namely, four­foot medium bi­pin, two­foot U­shaped,

3 eight­foot slimline, and eight­foot, recessed, double4 contact, high output ­­ and two wattage bins within

those lamp types. For each one of those lamp

6 categories EPCA established a minimum average lamp

7 efficacy standard and a minimum CRI standard.

8 First, I'm going to talk about the product

9 classes in the ANOPR as they relate to the minimum

average lamp efficacy standard, and then I will address

11 the issue of minimum CRI standards.

12 So, to establish product classes, DOE based

13 its product classes on two criteria: one, the type of

14 energy used, and two, the capacity of the product or

other performance­related features that justify

16 different standard levels, such as features affecting

17 consumer utility. For both fluorescent lamps and

18 incandescent lamps, the type of energy used is

19 electricity, which is not very much of a

differentiating feature, so we focused on the second

21 one. Where we saw differences in end utility and

22 differences in efficacy we established a separate

23 product class.

24 So the resulting criteria that met that

description for fluorescent lamps were physical

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1 constraints of the lamp, lumen package, and correlated

2 color temperature. DOE did not use lamp diameter,

3 ballast interoperability, and lamp wattage as criteria

4 on which to base separate product classes.

Now I'm going to talk a little bit about each

6 of these criteria in more detail. In terms of physical

7 constraints of lamps, the physical constraints of a

8 lamp refers to ability of a lamp to use a particular

9 fixture. DOE believes that the ability of a lamp to

use a particular fixture affects the utility of that

11 lamp. For example, lighting designers may feel that

12 certain fixtures are more appropriate for certain rooms

13 than other fixtures.

14 Because the efficacy of the product is also

affected by a fixture ­­ for example, four­foot lamps

16 and eight­foot lamps exhibit different efficacies ­­

17 DOE feels that physical constraints of lamps is an

18 appropriate criteria on which to base its product

19 class.

So the result of this would be that straight21 shape lamps and U­shape lamps would have different

22 product classes, and four­foot length lamps and eight23 foot length lamps would have separate product classes.

24 A second criteria on which DOE will base its

general service fluorescent lamp product classes is

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1 lumen package. Lumen package refers to the quantity of

2 light a lamp and ballast systems provides to the

3 consumer. DOE has noticed that there are in some cases

4 noticeable differences in lumen output between

different types of lamps. For example, eight­foot,

6 single­pin, slimline lamps and eight­foot, recessed,

7 double­contact, high output lamps have approximately a

8 50 percent difference in lumen output. DOE believes

9 that this affects the utility of those products.

In addition to having a substantial

11 difference in lumen output, these two lamps also show

12 an efficacy differential that can be as much as 10

13 percent between comparable slimline lamps and high

14 output lamps.

Therefore, given the differences in utility

16 and efficacies, DOE, in the ANOPR, establishes separate

17 product classes for eight­foot, single­pin, slimline

18 lamps and eight­foot, recessed, double­contact, high

19 output lamps.

Finally, the third criteria which DOE uses to

21 establish general service fluorescent lamp product

22 classes is correlated color temperature. Correlated

23 color temperature, or CCT, is a measure of the

24 perceived color of the white light emitted from the

lamp. DOE believes that it is a performance­related

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1 feature that affects consumer utility.

2 In addition, DOE believes that CCT affects

3 the efficacy of the lamp as well. Higher CCT lamps

4 emit less radiation in the visible part of the

spectrum, resulting in relatively lower efficacies.

6 As you can see on this figure on the right,

7 it's an example of average efficacies of four­foot,

8 medium, bi­pin lamps. You can see that the 4,100

9 Kelvin lamps exhibit on average higher efficacy than

the 6,500 K lamps. Given that information, DOE

11 considers setting separate efficacy standards for lamps

12 with CCT less than or equal to 4,500 K and lamps with

13 CCT greater than 4,500 K.

14 As I stated before, there are several

criteria on which DOE does not base its product classes

16 on for general service fluorescent lamps. DOE does not

17 subdivide product classes by lamp diameter. For

18 example, our T12 lamps are in the same product class as

19 our T8 lamps. DOE does not believe that these are

properties that affect lamp utility because right now

21 in manufacturer product literature and market trends we

22 see that T8 lamps are being offered as replacements for

23 T12 lamps.

24 In addition, as a related issue, DOE is not

subdividing product classes by ballast

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1 interoperability. Using the same example, T8 lamps and

2 T12 lamps require different ballasts, but DOE is

3 treating them to be in the same product class.

4 DOE understands, though, given some standards

on T8 and T12 lamps may not allow T12 lamps to be

6 available in the market and that would require

7 replacement of the ballast, DOE takes those economics

8 of purchasing another ballast as a replacement into

9 account in its life­cycle cost and national impact

analyses, as we'll discuss later on today.

11 Finally, DOE does not subdivide product

12 classes by lamp wattage. For example, the 40­watt,

13 four­foot, medium, bi­pin T12 lamp and the 34­watt,

14 four­foot, medium, bi­pin T12 lamp are in the same

product class. This is because DOE doesn't believe

16 lamp wattage is a property that necessarily affects

17 lamp utility, and we see that by 34 watts being offered

18 as replacements for 40­watt lamps.

19 Now that I've touched on the criteria on

which DOE based its general service fluorescent lamp

21 product classes, I'd like to touch on the issue of the

22 CRI standard. As I said earlier, EPCA established CRI

23 requirements that depend on lamp wattage. They have

24 separate CRI requirements for higher wattage lamps and

for lower wattage lamps.

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1 However, as I just stated, DOE is not

2 proposing ­­ or, is proposing to not subdivide its

3 product classes by lamp wattage. As you can see, that

4 creates a bit of a problem in how we want to deal with

the CRI standard as it exists right now in the product

6 class structure proposed in the ANOPR.

7 In addition, after the framework,

8 stakeholders submitted comments suggesting that DOE

9 change the CRI standard. Right now DOE believes that

it doesn't have the authority to change the CRI

11 standard.

12 So, DOE invites comment on the possible

13 approaches to handling the issue of CRI in the GSFL

14 efficacy standards.

MR. BROOKMAN: Pam.

16 MS. HORNER: Pam Horner, NEMA Lamp Section.

17 This is regarding Section 3(A)(2)(a)(2), specifically

18 the subject of other class­setting factors that were

19 not adopted. In principle, NEMA is interested in this

simplified approach. Simple is good. It excludes

21 certain factors that had been previously included, as

22 you mentioned, such as CRI, and we applaud any effort

23 to streamline and to simplify.

24 However, in our comments we wanted to give

you a heads­up that in our written comments we are

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1 going to include some other factors for consideration

2 because there are some downsides to excluding these

3 factors.

4 For example, CRI. If you take a look ahead

and look at the Candidate Standard Level 1, one sees,

6 if you analyze it, that you could in effect have T12

7 halophosphor lamps that wouldn't meet the standard but

8 T8 halophosphor lamps that would. Now, what tool do

9 you use to ensure that the appropriate energy efficient

lamps remain in the market?

11 It is possible, and this is where we need a

12 little bit more time. It is possible that if you

13 carefully select an LPW you might be able to do that.

14 But another obvious tool is CRI. So we simply want to

give you a heads­up on that today, and we will include

16 far more detail in our written comments.

17 The other issue, of course, is lamp diameter.

18 I know many of us during the interview period

19 expressed an interest in showcasing lamp diameter and

analyzing lamp diameter for a lot of reasons. I'd just

21 like to say at this point, and we will say more in our

22 written comments, that DOE notes a 10 percent

23 differential between slimline and HO systems, for

24 example. So there are differences according to

operational types.

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1 But there is at least that sort of

2 differential in the four­foot category between a T8 and

3 a T12. So, in other words, diameter matters.

4 So it is difficult; you're absolutely right.

And while we're fascinated with and appreciate the

6 efforts to streamline and understand the work that goes

7 into all of these analyses, I guess we're not so ready

8 to throw these out as considerations. Thank you.

9 MS. GUPTA: Thank you.

MR. BROOKMAN: Andrew Delaski.

11 MR. DELASKI: Clarifying question. I missed

12 your point about the 10 percent difference. What was

13 your ­­

14 MS. HORNER: There can be 10 percent efficacy

differences based on diameter. And some of these truly

16 also relate to the very kinds of, ultimately, the

17 ballasts upon ­­ with which these are associated,

18 because T8 lamps today ­­ and everyone is nodding. We

19 know this. The T12 operate for the most part on

magnetic, the T8 on electronic. There are a lot of

21 differences here, so we're not ready to throw out

22 diameter as a consideration. Thank you.

23 MR. BROOKMAN: Thank you. Other comments on

24 the logic behind the class differentiation?

MS. GUPTA: Yeah, a couple more comments, or

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1 request for comment are coming up on the next slide.

2 MR. BROOKMAN: Okay. Keep going, then?

3 MS. GUPTA: Yeah. So this slide just shows a

4 summary of the product class structure considered in

the ANOPR. As you can see here, we have separate

6 product classes for the four lamp types, and we create

7 product classes within each one of those lamp types for

8 lamps with CCT less than or equal to 4,500 K and lamps

9 with CCT greater than 4,500 K.

So here we ask for a few more detailed

11 comments, which Pam addressed some of them. So, DOE

12 invites general comments on the GSFL product classes.

13 Specifically, we invite comments on whether T12 and T8

14 lamps should be part of the same product class and also

on the CCT divider, whether there should be one, how

16 many there should be, and where the appropriate

17 dividers should be.

18 MR. BROOKMAN: Pam. Joe.

19 MR. HOWLEY: Yes, just a follow­up comment on

the T8 versus T12 product class divider for four­foot

21 lamps. NEMA feels that there really should be a

22 product class divider here. As the comment Pam made

23 before, and Andrew's follow­up question, we note that

24 when you're considering why you split into two

different products classes eight­foot slimline and

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1 eight­foot high output, one of the reasons was there

2 was a difference of about 10 percent in efficiency

3 between those two types.

4 So if that was a reason to split the eightfoot high output and eight­foot slimline, certainly the

6 difference between T12 and T8 four­foot is even greater

7 than 10 percent. So if that represents a reasonable

8 rationale for splitting those two categories, certainly

9 that would still apply for the four­foot T8 and T12.

It's just there's a significant efficiency difference

11 between those two product classes and the four­foot

12 type.

13 MR. DELASKI: Just a follow­up to Joe.

14 MR. BROOKMAN: Yeah. Go ahead, Andrew, and

then to Mike Rivest.

16 MR. DELASKI: Just to be clear, the T8 is 10

17 percent more efficient; is that ­­

18 MR. HOWLEY: At least.

19 MR. DELASKI: At least, in your catalogue, or

industry­wide generally. I just want to be clear on

21 what the comparison is.

22 MR. BROOKMAN: Okay. Mike Rivest.

23 MR. RIVEST: Yes. Mike Rivest. This is a

24 complicated issue, and this is an underlying theme of

this analysis, is that because this is a system this is

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1 a more complicated analysis. We had a lot of internal

2 debates and questioning about the appropriate thing to

3 do.

4 What we did try to do is to provide an

analysis that, with what you will see, have multiple

6 baselines. Multiple baselines is a way of capturing

7 the separate impact, say, of T8s and T12s without

8 separating them into product classes.

9 I think ultimately the right thing to do

depends on your policy objective. Creating a product

11 class has an implication in terms of what standards you

12 can set. So by creating a product class for T12s and

13 creating an economic justification for a higher T12

14 standard, for example, that becomes constraining.

We'll see that as the analysis develops today.

16 So I'd like everyone to keep an open mind

17 about what the right thing to do is as you think

18 through the implications of the economic justification

19 at every step of the analysis, bearing in mind that

we've tried to give the best of both worlds on the

21 analysis, something that combines the effect yet very

22 simply would allow you to see the separate impacts of

23 each CSL on different baseline lamps.

24 MR. BROOKMAN: Ron Lewis.

MR. LEWIS: I'd also be interested in input

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1 on slimline versus high output. Generally, a lighting

2 designer would not be using one as a replacement for

3 the other. They would be used for different

4 applications. Considerably different characteristics

of those lamps and the luminaires that would be using

6 them.

7 The T8 versus T12 as replacements one for the

8 other and how they're applied in looking at the

9 migration of one to another, how that fits into play.

I mean, they are the same dimension. The target lumen

11 packages or applications where they're used versus a

12 slimline, versus high output. Any clarification you

13 could give us there to help us would be appreciated.

14 MR. BROOKMAN: Joe.

MR. HOWLEY: I think the bottom line is, we

16 talked about constraints. I think it produces a

17 different constraint when you put the two product

18 classes together. Although it may be true they're used

19 in similar applications, they do need separate

ballasts, and there are more and more T8 fixtures made

21 today that are smaller, slimmer, that indeed will not

22 fit a T12 lamp. So there even are some differences

23 within the fixture types themselves between the two.

24 But the main constraint is we do not believe

it will ultimately be possible to set a lumen­per­watt

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1 standard that makes sense for T12, that this same exact

2 standard makes sense for T8s. I think that is

3 ultimately a constraint that's going to be difficult to

4 get around, saying that one number would be equally

effective for both product classes.

6 Given that that is the key outcome of this

7 entire analysis, I think that produces an unworkable

8 final solution, to have one lumen­per­watt standard

9 cover both. I believe that you need two product

classes because you're going to end up with two

11 different lumens­per­watt number that make sense for

12 T12 and that would make sense for T8. Thank you.

13 MR. BROOKMAN: Thank you. Follow on with

14 Mike Rivest. Steve, I'm coming to you. Let's keep

this all contiguous here. Go ahead, Mike.

16 MR. RIVEST: Mike Rivest. The difficulty

17 might be to be able to establish a T12 standard at all

18 if it's a separate product class. That's my concern.

19 And you know, this is a policy issue. It's a legal

issue in terms of how the economic justification is

21 handled.

22 Just to give you my thinking on that, one of

23 the important analyses is the life­cycle cost analysis.

24 As we look at the consumer economics on those

consumers of T12 lamps, what are the implications of

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1 increasing the efficacy requirement on the T12 lamp if

2 there is no low wattage option available. It would

3 mean that they would be paying more, getting more

4 light, but not saving energy.

So at the consumer level, the single consumer

6 level, we couldn't show an LCC saving of a T12

7 standard. We could show a net national energy savings

8 benefit of a T12 standard when one considers the

9 substitution effect of a higher cost T12 lamp migrating

more people towards the T8.

11 So here, because of the separate criteria for

12 consumer economics at the single level and the

13 aggregate impacts on the nation, we get this strange

14 situation that I haven't encountered in other rules

where we can't make an LCC case for T12, we can make a

16 national impact case. By combining the product

17 classes, it does constrain you to a single level,

18 that's true.

19 But as the presentation unfolds and we try to

present how that level would cut across the existing

21 products. You know, if we can work this problem

22 together I think is ­­ but what I just explained was

23 the rationale, or one of the rationales, for ­­ at

24 least for the moment looking at regulating them at the

same level.

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1 MR. BROOKMAN: Steve Nadel.

2 MR. NADEL: Yes. We strongly support what

3 DOE has done to combine these two classes, the medium

4 bi­pin, including the T8 and T12. They do compete in

the marketplace. People are making decisions. Gee, do

6 I want a T8 or a T12 fixture. Do I replace the ballast

7 or not. That's what happens in the marketplace.

8 What matters is, you know, there is very

9 large energy savings at stake here. If you start

splitting them up I think you may dramatically reduce

11 the potential energy savings, you know, by a factor of

12 two or more. So we see this as being a critical issue.

13 I would note that we have problems with the

14 argument that, gee, if efficacy varies we need to have

two standards. I don't see it that way at all. That

16 could be used to argue, gee, we need to maintain

17 separate product classes for almost any inefficient

18 product. I think what's much more important is not the

19 efficacy difference but the performance difference. In

this case, the high output lamp has a much higher light

21 output, and that is a performance difference. That I

22 support being a rationale for a separate class for HO,

23 but not the fact that it's an efficacy difference.

24 I would also note that, per the earlier

discussion, and this had to do with test procedures,

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1 but it may make sense to have a T5 class as well. In

2 terms of CRI, my tendency is to think we probably don't

3 need it. But I agree with Pam; we should hold it in

4 reserve to see if that's going to be an important

differentiator.

6 As Pam was kind of alluding to, we don't ­­

7 presently in the United States, as far as I know, there

8 is no halophosphor T8. We don't want to encourage

9 people to start introducing those products in order to

get around a standard. So if the efficacy doesn't

11 work, we should be open to CRI.

12 I don't recall anything in the law

13 prohibiting DOE from revising the CRI standard. So I

14 would encourage we keep it on the list of options even

if it is, maybe, not the primary thing. Hopefully LPW

16 will be an adequate differentiator.

17 MR. BROOKMAN: Mike Rivest.

18 MR. RIVEST: Again, CRI analytically proves

19 to be difficult because it's not something that ­­

first of all, it's not an efficiency metric. The way

21 it correlates with efficiency is it tends to be a

22 positive correlation. So it's hard to analyze the

23 benefits of one or another CRI directly.

24 Now, maybe we just haven't captured it

correctly, but for the present time it's proved to be a

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1 challenge to look at the differential impacts of one

2 pairing versus another pairing, say.

3 MR. BROOKMAN: Let's let Steve finish, and

4 then Andrew.

MR. NADEL: Right. And I'm not saying do

6 lots of analysis based on CRI. I agree. Hopefully

7 this will all work out. But because one of the

8 objectives as noted in the ANOPR is to prevent opening

9 up loopholes and we don't want to encourage the

introduction of products, you know, if an LPW doesn't

11 keep a T8 halophosphor product from being introduced,

12 adding a CRI to that standard may be an appropriate

13 one.

14 MR. BROOKMAN: Andrew Delaski.

MR. DELASKI: I think you've heard twice now

16 this morning that there are a couple of spots in this

17 analysis where your analysis may have nothing to say on

18 the topic but that are crucial to how the rulemaking

19 proceeds. I think this is something that comes up in

lighting that we don't see in other products.

21 It happened in 1992 in reaction to the EPACT

22 reflector lamp standards. I don't think anybody

23 analyzed what would happen if exempted lamps took 60

24 percent of the marketplace. California analyzed what

happens if vibration service lamps become ipso facto, a

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1 conventional product in the marketplace.

2 So, as you noted, and I think it's on the

3 opening slide in the product class discussion, that we

4 have to watch out for loopholes here. We have to watch

out that if something has ­­ some of the little stuff

6 becomes the big stuff. It's a tiny piece of the

7 market. They are not even this big. I think Pam

8 indicated that the halophosphor T5 is nonexistent. You

9 can't analyze cost effectiveness because it doesn't

exist in the marketplace.

11 I think it is incumbent on the Department to

12 protect against the loss of energy savings that would

13 happen if these loopholes were to open up in response

14 to the Department's actions. That doesn't fit into

your analysis but it's still something you have to

16 protect against.

17 MR. RIVEST: I understand.

18 MR. DELASKI: Whether it's the T5 issue,

19 whether it's this issue, whether it's ­­ Pam mentioned

the U­bend lamps that didn't exist when you first

21 started this analysis. We could have lower wattage

22 lamps that don't exist today, below some of the levels

23 that you're looking at, that may or may not be a

24 problem in terms of energy savings that have to be part

of the Department's consideration in this rulemaking.

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1 MR. BROOKMAN: Pam.

2 MS. HORNER: Pam Horner for the NEMA Lamp

3 Section. You've heard that a few times. I'd like to

4 comment, please, briefly on your last question

regarding correlated color temperature and update you

6 briefly on something that the NEMA Lamp Section is

7 doing. It goes back or is related to the revised

8 definition of colored fluorescent lamps. Are you with

9 me here? So it's related to your question.

We tend to agree with the revised definition,

11 but what it does ­­ and this whole thing, for everyone

12 here, if you don't know what I'm talking about, is if

13 you look at her previous slide, it has a distinction

14 made between lamps of less than or equal to 4,500

Kelvin, which would capture the main kinds of

16 correlated color temperatures that you find in the

17 market today for common application. It then gives a

18 second set of product classes for greater than 4,500

19 Kelvin.

This looks good, except something new has

21 happened in the market. That is that not only lamps of

22 great ­­ well, lamps of greater than 4,500 Kelvin, the

23 ones that look bluer, are now spreading out into higher

24 and higher numbers. Probably this was originally

intended to capture your 5,000 Kelvin lamps that are

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1 becoming very common in utility rebate programs. Very

2 high interest in these lamps.

3 But what is happening in the market, and

4 we're here to tell you, is that even higher color

temperatures are entering the market not just for

6 special applications. The definition said why don't we

7 just say if it's for special applications, it's for

8 special applications and you market that way. But for

9 example, there's an 8,000 Kelvin lamp that is rapidly

becoming of interest in the market that could be used

11 for both specialty and general applications.

12 I mean, you could sort of not tell the truth

13 exactly on your packaging, I suppose, but that isn't

14 really an option. So, how do we deal with this trend?

Several months ago, our Technical Committee

16 set about getting the top phosphor scientists ­­ which

17 tend to live mainly in the big three lamp companies.

18 This was no small task ­­ to get them together under

19 the auspices of a NEMA Technical Section Taskforce to

examine the kinds of trends for higher­color

21 temperature lamps, knowing that this would come up and,

22 if asked, what would we say.

23 I wish we were ready today and we could have

24 a party or something, but unfortunately we are still

collecting how we would do this. But the initial

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1 indication is that there should be a third break.

2 Like, these are okay, but we think there will have to

3 be something around 5,500, something of that nature.

4 Don't hold me to that, please, because we'll put it in

our comments.

6 But we wondered if DOE would be interested.

7 The minute we get all of our findings, would you be

8 interested in having a really nice technical summary of

9 what we analyzed and why, and we promise it would be

interesting? Okay. Because this is not a minor point.

11 It has to do with everything from machine speed to

12 coating thicknesses, to availability of phosphors, to

13 the different efficacies of different kinds of

14 phosphors. There seems to be a natural break that we

think will be helpful in your columnation.

16 I see some nods. I'm going to take that as a

17 yes. Thank you.

18 MR. BROOKMAN: Thank you. Yes, please. Your

19 name.

MR. WALITSKY: Paul Walitsky, Industrial

21 Ecology. What we found in Philips when I was active

22 there was that the further south we got in the country

23 the higher the color temperature went that people

24 preferred. So we were seeing, in the south and in

Mexico, in 98 percent of the sockets were daylight.

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1 And it was a geographical spread as well as preference.

2 So that, I think, reinforces some of what Pam

3 may be getting to. The 5,000 K lamp was popular for a

4 while. We used to see 6,500 only for special printing

applications, but now it's getting into general

6 lighting. So they have moved exactly in those

7 directions.

8 MR. BROOKMAN: Thank you. So, Pam, thanks

9 for those remarks. Let me note for the record that DOE

would be very interested in receiving that kind of

11 detailed analysis to supplement their work.

12 Okay. So, any other comments, then, before

13 we return to Mimi?

14 (No response.)

MS. GUPTA: All right. So now that we've

16 discussed the general service fluorescent lamp product

17 classes I'd like to move on to the incandescent

18 reflector lamp product classes. EPCA set efficacy

19 standards for six different wattage bins for

incandescent reflector lamps. DOE believes that

21 wattage, though it affects efficacy, is not a measure

22 of utility and merely a measure of power. For example,

23 a high efficacy, 55­watt lamp can deliver the same

24 amount of light as a lower efficacy 75 watt lamp.

So if DOE were to maintain the wattage bins

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1 as they exist in EPCA, DOE's analysis could not

2 consider the 55­watt lamp as a replacement for the 75­

3 watt lamp since they would be in separate product

4 classes.

Therefore, DOE establishes a product class

6 that encompasses the entire wattage range covered, 40

7 watts to 205 watts. To take into account the effect of

8 wattage on efficacy, DOE is proposing that the

9 candidate standard level for incandescent reflector

lamps would be an equation that depends on wattage.

11 So here you see an illustration of the EPCA

12 standards. It's a step­like standard. As you can see,

13 as lamp wattage increases, the efficacy standard

14 increases as well. You can also see here the form of

the ANOPR candidate standard levels for incandescent

16 reflector lamps. Similarly, as efficacy increases, or

17 as wattage increases, we have efficacy increasing.

18 DOE is establishing product classes by

19 modified spectrum for incandescent reflector lamps in

the ANOPR. As discussed earlier in the scope of

21 coverage section, EISA 2007, or the Energy Independence

22 and Security Act, defines a colored lamp such that some

23 incandescent reflector lamps ­­ for example, lamps

24 containing greater than 5 percent neodymium ­­ are no

longer excluded from energy conservation standards

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1 coverage.

2 These lamps may fall under the definition for

3 modified spectrum also incorporated by EISA, which

4 defines modified spectrum as a lamp that is not a

colored lamp and a lamp whose color point with

6 chromaticity coordinates lies below the black body

7 locus and at least four macadam steps from the color

8 point of a similar clear lamp.

9 DOE believes that modified spectrum IRL offer

different light output and therefore utility. Because

11 they absorb a portion of the visible spectrum, visible

12 light emission of the filament, they exhibit a reduced

13 efficacy. Therefore, DOE considers establishing a

14 separate product class for modified spectrum lamps.

This slide shows a summary of DOE's

16 incandescent reflector lamp product classes. We have

17 two product classes. Each one spans the full wattage

18 range. So you have one product class for standard

19 spectrum IRL and another product class for modified

spectrum IRL.

21 I'd like to open the floor for comment on the

22 IRL product classes.

23 MR. BROOKMAN: Pam.

24 MS. HORNER: Surprise. Pam Horner for the

NEMA Lamp Section. We like that smoothing formula.

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1 It's a very good idea, and we think the rationale was

2 very well thought out.

3 We do have one concern that we're going to

4 elaborate upon in our written comments that we would

like to give you, again, a little heads up on. In the

6 description of what one must do in order to get at the

7 difference between a modified spectrum lamp and a

8 standard spectrum lamp, it seems to us that the

9 responsibility for getting the correct baseline

efficacy falls to the manufacturer, which is rather

11 interesting.

12 In other words, you have a clear lens, then

13 you have to carefully take it off, put on the modified

14 spectrum lens, et cetera. The process, according to

the people who wear white lab coats in our company,

16 they find to be extremely complicated.

17 We are a little bit concerned about how it

18 might be enforced and verified the way it's written, so

19 we thought it would be an opportunity for us, too, if

we can have some improvements suggested in those areas.

21 We will provide those in writing. Thank you.

22 MR. BROOKMAN: Thank you. Thank you very

23 much. Additional comments on these IRL product classes

24 and the way they're described? Yes.

MR. FERNSTROM: Gary Fernstrom, PG&E. We

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1 noticed that DOE in its Footnote 28 indicates the

2 modified spectrum lamps provide a unique utility to

3 customers in that they offer a different spectrum of

4 light from the typical incandescent lamp. However, we

think DOE's conclusion differs a little bit from the

6 LRC's conclusion having to do with the utility of these

7 lamps. We would like to see that further investigated.

8 We don't think that modified spectrum

9 incandescents offer very much utility consumers that

can't be better achieved through fluorescent or other

11 types of light sources.

12 MR. BROOKMAN: Thank you. Steve Nadel.

13 MR. NADEL: A question first, as I'm trying

14 to understand this. How do you define modified

spectrum? Where is the line between normal spectrum

16 and modified? Because, you know, there's the potential

17 to game this. Oh, I tweaked it, you know, to a minor

18 degree.

19 MS. GUPTA: Yeah. Well, EISA 2007

establishes a definition for a modified spectrum.

21 MR. FERNSTROM: Okay. So you would use that

22 definition.

23 MS. GUPTA: Yeah, we would have to. It's

24 actually that definition that incorporates the idea of

the clear lamp. So in order to get this break for a

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1 modified spectrum, you would already have to do that

2 measurement between the clear lamp and the modified

3 spectrum lamp, referring back to Pam's point.

4 MR. BROOKMAN: Go ahead, Steve.

MR. NADEL: I guess, to make a comment, I'll

6 somewhat agree with Gary that we're not clear what the

7 extra utility is and how much of a benefit it is.

8 We're concerned that potentially this could result in

9 lost energy savings. So as part of any analysis ­­

we'd recommend that DOE not make a decision but do an

11 analysis and see what the impacts are on energy saving

12 as part of this analysis before making a decision.

13 MR. BROOKMAN: Andrew Delaski.

14 MR. DELASKI: I'm curious if the Department

has any data at this point on what market share

16 modified spectrum reflectors have.

17 MS. GUPTA: No, we don't have any data at

18 this point. The only data we have is looking at

19 manufacturer product literature. We can see that there

are relatively lower numbers of incandescent reflector

21 lamps that are modified spectrum than there are general

22 service incandescent lamps, but we would appreciate any

23 data on that.

24 MR. DELASKI: Do you all have any NEMA

manufacturers or certain NEMA ­­ do you have any

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1 information you can share on that at this time on what

2 your take is?

3 MR. HOWLEY: ­­ indicate it's a relatively

4 low percentage of the market.

MR. BROOKMAN: Joe says no specific data at

6 this time.

7 MR. FERNSTROM: Gary Fernstrom, PG&E. I'd

8 just like to point out that perhaps one way to

9 estimating market share without actually having that

information is looking at shelf space in retail. PG&E

11 noticed a significant shelf space in retail devoted to

12 modified spectrum lamps.

13 MR. BROOKMAN: Thank you.

14 MS. GUPTA: That includes modified spectrum

incandescent reflector lamps, also. Okay.

16 MR. BROOKMAN: Yes, Ron Lewis.

17 MR. LEWIS: If NEMA or anybody, if IES or

18 ANSI has a definition of what modified spectrum is,

19 even if we're looking at ­­ to my understanding,

everything is a filter. That's a deductive process as

21 opposed to additive. So, much like on the straight

22 line curves versus the step function, here this looks

23 like it's a continue ­­ anybody could do anything.

24 Where is that line as far as modified spectrum that

applies ­­ that's a deductive efficacy or the spectrum.

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1 In trying to get our arms around what is it

2 that we're dealing with here, it's not a discrete point

3 of a single step of this is modified spectrum. But,

4 what is the range or how do we get our arms around a

definition of modified spectrum for incandescent

6 reflector lamps specifically?

7 MR. BROOKMAN: Joe.

8 MR. HOWLEY: Yes, this is Joe Howley. There

9 is a definition of modified spectrum which was worked

out in the EISA law, and that is in there. It has to

11 do with changing the color point off the black body

12 curve a certain number of degrees to basically ensure

13 that a heavy amount of filtering was occurring, that

14 you were going after the modified spectrum result.

But otherwise, what you're proposing is

16 exactly correct. You would need two separate product

17 categories. Under the old rulemaking you'll note that

18 this product category was exempted. Under this

19 rulemaking, EISA basically takes away that exemption

but provides a definition. If these were to be further

21 regulated as you're proposing, there would definitely

22 need to be two product categories, as you're proposing,

23 one for clear lamps and one that, as you said, has a

24 filter on it removing the yellow part of the spectrum

and producing a lower lumen­per­watt level. So that

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1 would need its own separate category, as you're

2 proposing.

3 So we're basically supporting your proposal.

4 There are some questions about how you might test for

that, but other than that, on the high level we support

6 your proposal to have two separate categories.

7 MR. BROOKMAN: Thank you. Jeff Harris.

8 MR. HARRIS: Jeff Harris, Alliance to Save

9 Energy. I wonder, Joe or somebody else from the

manufacturer side, if you can tell us anything about

11 the cost difference for modified spectrum reflector

12 lamps. Is it roughly the same magnitude as the cost

13 difference for the conventional GLS lamps?

14 MR. BROOKMAN: Hey, Joe, let's get it on the

record. Why don't you leave that mic on?

16 MR. HOWLEY: Essentially, the same glass is

17 used. So, yes, there would be a cost adder whether or

18 not you're forming it into an A­line bulb or you're

19 putting it into a reflector type bulb. You're using

the same kind of glass or same kind of coatings. But

21 the cost adders would still be there.

22 MR. BROOKMAN: Thank you. So, other comments

23 on this spectrum of issues?

24 (Laughter.)

MR. BROOKMAN: I see none. Okay. So let's

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1 do two more slides and then we'll break for lunch.

2 MS. GUPTA: Okay. My colleague Conan

3 O'Rourke will talk a little bit about the screening

4 analysis next.

MR. O'ROURKE: Thank you, Mimi. In the

6 screening analysis, the Department goes through looking

7 at the different possibilities of the technology

8 options that were identified and whether they should or

9 should not be screened out and will later become design

options. The criteria they look at are technological

11 feasibility, the practicability to manufacture,

12 install, and service, as well as adverse impacts on

13 product utility or product availability, and also

14 looking at impacts on health or safety.

The design options that were at least

16 selected for consideration ­­ I'll read them ­­ for the

17 general service fluorescent lamps are high­emissive

18 electrode coatings, high efficiency lamp fill gas, high

19 efficiency phosphors, glass coatings, and high

efficiency lamp diameters.

21 For the incandescent reflector lamp design

22 options, they are the high temperature operation,

23 thinner filaments, efficient filament coiling,

24 efficient filament orientation, higher efficiency inert

fill gas, tungsten­halogen lamps, higher pressure

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1 tungsten­halogen lamps, infrared glass coatings, and

2 high efficiency reflector coatings, as well as

3 efficient lamp placement.

4 Next, moving into the engineering analysis,

the purpose of the engineering analysis is to take the

6 ­­

7 MR. RIVEST: Doug?

8 MR. BROOKMAN: Yes.

9 MR. RIVEST: This is probably a good place to

break.

11 MR. BROOKMAN: I was wondering. I thought so

12 as well. Comments on these last two slides, 17 and 18?

13 Yes, Pam.

14 MS. HORNER: Pam Horner with NEMA Lamp

Section. Regarding the technology assessment and

16 screening analyses that were performed, first, for

17 fluorescent, we agree. For incandescent reflector, we

18 agree in general with the technologies that were

19 considered for improved efficacy, as long as they apply

to 40­watt to 205­watt. It never said anywhere in here

21 that that remains the wattages that are regulated; is

22 that correct? Okay. So as long as that is the case,

23 then we're okay.

24 We also believe the DOE screened out the

appropriate ones and left a reasonable list. We have

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1 some updated information for you, however, on one of

2 them that could become a caveat as we move forward in

3 trying to improve efficacy in the incandescent

4 reflector lamp. Again, it's nothing ­­ you can't count

on these things. Like Andrew says, things just keep

6 popping up.

7 We just learned, for example, that on certain

8 contracts for xenon gas ­­ xenon gas happens to be the

9 real reasonable next step up above krypton for the

improvement of efficacies in these certain lamp types,

11 especially in the halogen world. You talk about

12 limited supply and cost increase. It went up seven

13 times over the last three months in a recent contract

14 analysis we did.

For some reason there is a major shortage, so

16 there is a sudden concern about what would have been a

17 viable gas fill option. It's driving us crazy,

18 basically. We even learned that, just as an example,

19 one of the competitors for this is the federal

government and its space program. Now, we're not

21 saying that that's the only competitor for the

22 technology, but these things happen.

23 So we thought it would be useful for you to

24 know that even though the analysis was excellent these

sorts of things can happen and impact our future.

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1 MR. BROOKMAN: Thank you. Thanks for that

2 clarification. Other comments on the selected design

3 options featured on Slide 18? Steve Nadel.

4 MR. NADEL: Yes. One of the consultants

5 we're working with is looking at this list, and what I

6 heard from some preliminary results is we wonder

7 whether DOE may have cut out too many. I don't have

8 more particulars at this point, but we may be

9 commenting on that.

10 MR. BROOKMAN: Thank you. The sooner the

11 better, I'm certain. Yes. Additional or perhaps final

12 comments on these design options?

13 (No response.)

14 MR. BROOKMAN: Okay. So let's take lunch

15 now. It's 10 minutes after 12.

16 (Whereupon, at 12:10 p.m., the meeting was

17 recessed for lunch, to reconvene at 1:13 p.m., the same

18 day.)

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1 A F T E R N O O N S E S S I O N

2 1:13 p.m.

3 MR. BROOKMAN: A few people made it here late

4 because of delays and other kinds of things and didn't

get a chance to introduce themselves. I want to

6 provide that opportunity to anyone that didn't have a

7 chance to introduce him­ or herself. Mark, I think you

8 were one.

9 MR. FRIEDRICHS: No, I introduced myself.

MR. BROOKMAN: Oh, you did. That's right,

11 you did. Okay. I guess maybe I'm mistaken. So then

12 that courtesy is now fulfilled. Conan.

13 Engineering Analysis (Continued)

14 MR. O'ROURKE: Thank you, Doug. I'll begin

our after­lunch discussion dealing with the engineering

16 analysis. The engineering analysis is used in

17 conjunction with the product price determination to

18 look at developing a relationship between energy ­­

19 higher efficiency products and the cost of those higher

efficiency products. These two things, the engineering

21 analysis as well as the product price determination,

22 feed together into later analyses on life­cycle cost

23 and on the payback period analysis, as well as the

24 national impact analysis.

MR. BROOKMAN: We're on Slide 19, correct?

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1 MR. O'ROURKE: Yeah. I just moved on to 20.

2 MR. BROOKMAN: Okay.

3 MR. O'ROURKE: So Slide 20 is meant to be a

4 summary of the main steps of the engineering analysis.

Choosing the representative product class. Here,

6 that's one which will be selected to be the engineering

7 and the life cost analysis.

8 Define the basic model. That basic model is

9 developing the characteristic models for each of the

representative product classes and service reference

11 points when we look at higher representative products

12 and candidate standard levels when we move on from

13 there.

14 Selecting the efficient substitutes.

Basically, looking at products that we gathered from

16 manufacturers' literature in developing a comprehensive

17 list of what is on the market. We looked at

18 substitutes that would maintain similar light output as

19 well as save energy.

Then, the next step is developing candidate

21 standard levels. These span the range of what kind of

22 meets energy standards today all the way up to what's

23 maximum technology feasible.

24 The last step is scaling the product classes

that weren't analyzed from the ones that were analyzed.

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1 That would be the last step.

2 So, representative product classes. The

3 Department selected a subset of the product classes, as

4 we showed earlier, of the eight that would be analyzed

for the engineering analysis and the life­cycle cost

6 analysis. The ones that were chosen were based on

7 highest volumes of shipment, ones that were common in

8 the marketplace. The ones in particular are the four9 foot, medium, bi­pin with a correlated color

temperature of less than or equal to 4,500; the eight11 foot, single­pin, slimline lamps also less than or

12 equal to 4,500; and finally, the eight­foot, recessed,

13 double­contact, high output, the same CCT requirement.

14 For incandescent reflector lamps, we looked

at standard spectrum lamps and scaled those findings to

16 the modified spectrum, which I'll discuss at the end.

17 Baseline models are developed from within the

18 representative product class. They're usually the ones

19 that would meet ­­ just bare minimum meet the existing

Energy Star energy standard. We selected the

21 particular attributes like light output, wattage, and

22 operating lifetimes that were typical for the most

23 common lamps for that baseline model.

24 It was mentioned earlier that there were

several different baselines for the product class, as

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1 Mike Rivest tried to comment on, how to handle the

2 different lamp diameters within the same product class.

3 We'll talk about that as well.

4 So, going down just to describe what these

baseline models are, we have the four­foot, medium, bi6 pin. We're looking at baselines of the 40­watt T12,

7 the 34­watt T12, and the 32­watt T8, with operating

8 lifetimes of 20,000 hours and a CCT of 4,100. That was

9 what was selected. We broke the phosphors up into

three different categories. In this case we're looking

11 at 700 series, which would be CRIs between 70 and 79.

12 We're also describing 600 series with CRIs between 60

13 and 69.

14 But I was just showing here that phosphors of

the 40­watt T12 and the 32­watt T8, their baseline

16 models are using 70 CRI lamps for 700 series, where the

17 34­watt T12 is using lamps with CRIs in the 60s.

18 For the eight­foot, single­pin, slimline,

19 we're looking at the 75­watt, the 60­watt T12s, and the

59­watt T8. The operating lifetimes here are 12,000

21 hours and 15,000 hours. The CCT is 4,100, and the

22 phosphors we're looking at here are also the 70s and

23 the 60 CRIs for this category as well.

24 The last one here for the recessed doublecontact, we're looking at the 110­watt and the 95­watt

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1 T12s, and we don't ­­ in this one we do not have a T8

2 baseline model because, based on the market data that

3 we got, the market is so small ­­ it's less than 5

4 percent ­­ that it wasn't considered for a baseline.

And operating lifetime here was 12,000 hours with 4,100

6 K and looking, again, at CRIs of 70s for the 110 and

7 60s for the 95­watt and the ­­ version.

8 So, once you have those baseline models, the

9 next step is looking at substitutes that you would get.

Here we're showing the table of these are all based on

11 commercially available product. These are just

12 examples of the four­foot medium bi­pin category. So

13 you see there are three different baselines there. The

14 first one in the first row, the T12, 40­watt, has a

rated efficacy of about 80 lumens per watt with a CRI

16 of about 70.

17 The other baseline is the T12 at 34 watts

18 with a 77.9 lumens per watt and a 62 CRI. The third

19 baseline is a T8 with 32 watts, 86.2 lumens per watt,

and CRI of 75. Then, all the remaining rows are

21 different, other representative products, substitutes

22 that you could have in those product classes.

23 Any questions on this table?

24 MR. BROOKMAN: Or other questions or comments

on the baseline models specified in 23, if you haven't

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1 done so already?

2 (No response.)

3 MR. O'ROURKE: Now, the next step we're

4 looking at systems because when you're comparing a lamp

to a lamp they're going to operate in an application

6 with a ballast. So that's the approach that was taken

7 in our analyses for the engineering and for the LCC.

8 It considers both the reduced wattage lamps and equal

9 wattage lamps.

In the case of equal wattage lamps, if you

11 have a more efficient lamp for the same wattage, you're

12 going to have more light output, not necessarily energy

13 savings. So to deal with energy savings you can use a

14 lower ballast factor ballast to compensate.

We realize that the ballast does influence

16 the amount of light you're going to get and also the

17 system power in that case. We looked at them paired

18 with more than one ballast in some cases for that

19 system.

Systems were chosen to have similar mean

21 lumen outputs as a baseline model. Again, energy

22 savings of the baseline model could be obtained by

23 either having a more efficacious reduced wattage lamp

24 on the same ballast or have a more efficacious and same

­­ reduced wattage lamp on a different ballast that

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1 would operate the lamp at a lower power level.

2 I'm going to have a graph up here in a moment

3 so you can see how this plays out.

4 So, just to go into how the systems would

work, we look at the system mean light output as based

6 on the number of lamps per ballast times the ballast

7 factor times the mean light output of the lamps. An

8 example would be if you had a three­lamp ballast with a

9	 0.9 ballast factor and the lamps were about 2,000 mean

lumens. Then the system lumens would be approximately

11 5,400 lumens, and that's what we would use kind of for

12 the system comparison.

13 System is dependent on the lamp wattage and

14 ballast factor. So as ballast factor decreases, the

system power would decrease as well. As the lamp

16 wattage decreases, it also reduces system power.

17 Here on Slide 27 we're looking at different

18 rated lamp wattages. As you reduce the wattage, you'll

19 see that there's a general shift up and to the left.

We're showing the rated lamp efficacy in lumens per

21 watt on the Y­axis.

22 The green arrows are meant to show changes in

23 lamp and ballast that would occur to take advantage of

24 these higher efficacious light sources and still try

and maintain light output. The yellow ones are showing

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1 the change in lamp only or it could be also lamp and

2 ballast changes. We also have a green arrow up here

3 that shows a transition of where it would occur going

4 from T12 technologies to T8 technologies.

We're also showing here where all the

6 baselines are starting out at. So here's a 40­watt T12

7 baseline at about 80 lumens per watt. Here's a 34

8 baseline, about 78 lumens per watt, and also, the T8

9 baseline at about 86 lumens per watt. Yes.

MR. NADEL: You have a bunch of vertical

11 green arrows. Are those supposed to be green in those

12 cases or are those supposed to be yellow?

13 MR. O'ROURKE: They're meant to be green

14 because they have to be a lamp and ballast change. It

can't just be a lamp only.

16 MR. NADEL: It can't be? You're going from

17 like a T12 ­­

18 MR. O'ROURKE: No, the vertical green are

19 just the same lamp type, the 32­watt T8. All I'm doing

is choosing a more efficacious 32­watt T8. But in

21 order for me to get energy savings, I have to be able

22 to reduce the system power by using a lower ballast

23 factor ballast.

24 MR. NADEL: Okay.

MR. O'ROURKE: I can't do it with the lamp

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1 alone.

2 MR. NADEL: Okay.

3 MR. O'ROURKE: But I'd have to replace the

4 ballast.

MR. BROOKMAN: Gary.

6 MR. FERNSTROM: Conan, Gary Fernstrom from

7 PG&E. What you're doing is you're showing us on the

8 left­hand axis, though, the efficacy. So you could get

9 an improvement in efficacy just as well by increasing

the lumens and keeping the watts the same.

11 MR. O'ROURKE: Right. Well, what would

12 happen, when you compared the systems you would have a

13 much different comparison in the overall lighting.

14 Unless if you were trying to compensate by trying to

maintain about the same light output.

16 MR. FERNSTROM: All right. So this is for a

17 nominal light output, or a consistent light output.

18 MR. O'ROURKE: Well, the way that these ones

19 get these higher efficacies for the same power is by

providing more light. So you have to be able to, if

21 you want to still keep about the same amount of light

22 for the system, you're going to have to use a lower

23 ballast factor ballast.

24 MR. BROOKMAN: Jeff.

MR. HARRIS: Jeff Harris, Alliance to Save

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1 Energy. Did you look at any conversions from a three2 lamp to a two­lamp configuration in the same fixture?

3 MR. O'ROURKE: We didn't. You'll see a

4 little bit later our systems that we set, what we're

going to analyze for each baseline model. In some

6 cases it was a three­lamp ballast, in some cases it was

7 a two­lamp ballast. But at this time we have not taken

8 in going from different number of lamps and comparing

9 them to each other.

MR. FERNSTROM: So, Gary from PG&E again. I

11 was surprised at that, too, because I think the two12 lamp might be more common. So, is there a reason why

13 you chose the ones you did?

14 MR. O'ROURKE: Only in that we believed at

the time they were the more common ones on the market.

16 I think it's also similar to what they did in the 2000

17 ballast rule as well.

18 MR. BROOKMAN: Mike Rivest, go ahead.

19 MR. RIVEST: Mike Rivest. So in terms of

selecting a representative system, one could have

21 chosen a two­lamp, three­lamp, or a four­lamp, or one

22 could have done the analysis with all three. You'll

23 see that as you try to anticipate what consumers will

24 do as they're faced with a more stringent standard,

there's already a very large range of choices that they

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1 have to make.

2 So, to keep the analysis tractable, we

3 elected with the three­lamps because what we saw based

4 on the 2000 analysis was that the average lamps per

electronic ballast was like 2.85. Where does this

6 matter. It matters primarily where you have to incur a

7 cost of a ballast and divide the cost of that ballast

8 over a certain number of lamps for your fixed cost. So

9 if we would have taken a two­lamp system, we would have

been overstating the cost of the ballast, and if we had

11 taken a four­, we would have been understating it.

12 MR. FERNSTROM: Thank you.

13 MR. BROOKMAN: Thank you. I thought I saw

14 someone else with a comment or a question. No? Okay.

MR. O'ROURKE: Okay. Going on, looking at

16 the baseline systems, the four­foot, medium, bi­pin,

17 three­lamp system has ­­ for the T12, could be a

18 magnetic or electronic system ­­ or a 0.88 ballast

19 factor with electronic ballast, excuse me, and the T8

would be a 0.88 ballast factor, electronic ballast.

21 Additional systems we would look at would

22 look at other ballast factors for the T12 system and

23 also other ballast factors for the T8 allowing for low,

24 medium, and high ballast factors.

For the eight­foot system, along the same

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1 lines, for the T12, the magnetic ballast or electronic

2 ballast with a 0.88 ballast factor, a T8 with a 0.88

3 ballast factor, electronic ballast. And, the number of

4 ballast factors available for these ballasts were a lot

less once you get up into this category of ballast for

6 the single­pins, so we don't have as many options to

7 choose from.

8 Going to the eight­foot, recessed, double9 contact, we only have, again, the T12 lamp as the

baseline. We have an electronic ballast for that, and

11 we're looking at two other ballast factors of 0.9 and

12 0.89. We are using T8 even though it isn't enough of a

13 market for a baseline. We're looking at least from the

14 analytical side of what would the analysis look like if

you included the T8 system with a 0.81 ballast factor.

16 So in summary, for at least I should say

17 introducing the candidate standard levels, once we have

18 now got all our representative substitutes that we're

19 going to use to compare to our baseline models, now we

can start to look at developing candidate and standard

21 levels. These would usually have several different

22 design options. Primarily we looked at ­­ we've been

23 discussing the different phosphors, but they could also

24 have other ones as well.

So the phosphors we've mentioned were the 600

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1 series, which are typically halophosphor lamps with

2 CRIs between 60 and 69, and they are usually

3 accompanied with reduced wattage lamps. The 700 series

4 have a rare earth phosphor, usually in some combination

with a halophosphor, but the primary addition is the

6 rare earth phosphor. It does have a higher wattage

7 baseline and higher efficiency lamps. These lamps have

8 CRIs between 70 and 79.

9 The last category of 800 series uses a more

rare earth phosphor and even more efficient lamps with

11 CRIs between 80 and 89.

12 The other possible design options that are

13 listed here besides just the phosphors are the emissive

14 coatings, higher efficiency lamp gas fills, thicker

phosphor coatings, glass coatings, and higher

16 efficiency lamp diameters. In some cases, the

17 candidate standard levels that are suggested do

18 eliminate T12 lamps.

19 MR. BROOKMAN: Joe, go.

MR. HOWLEY: Yeah, I just had some questions

21 concerning the T12 systems used for the baseline. I

22 noticed that you are using either magnetic or

23 electronic for the four­foot and the eight­foot

24 slimline, but only using magnetic ­­ electronic for the

eight­foot high output T12. It just seems unusual

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1 because most T12 systems, the overwhelming majority of

2 them, are used on magnetic systems only. with very few

3 of them being used in electronic. T8 is the other way,

4 where we recognize almost all T8 systems are run on

electronic ballasts, but almost all T12 systems are run

6 on magnetic ballasts because the driver there typically

7 is lowest first cost.

8 So in the contractor market, the contractor

9 either goes for the lowest first cost, which is T12

magnetic, or they go for most energy savings, which is

11 T8 and electronic. The middle market almost doesn't

12 exist.

13 So the baseline, especially the one where you

14 only include the electronic on eight­foot high output,

it just seems not like a typical system, so an unusual

16 system. Do you know why magnetic was not considered

17 there?

18 MR. O'ROURKE: I'll let Mimi comment on that.

19 MS. GUPTA: Mimi Gupta. The reason why we

used for high outputs only electronic T12 systems is

21 because shipments from the 2000 ballast rule indicated

22 that most high output ballast shipments were

23 electronic.

24 MR. HOWLEY: For the new. But the vast

majority of the installed base is magnetic.

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1 MR. BROOKMAN: Mike Rivest.

2 MR. RIVEST: The LCC, what it's doing is it's

3 comparing the situation where there's no standards to

4 one where there is standards. So although the

installed base might be magnetic, the presumption is

6 that ­­ am I saying ­­ is this correct?

7 MS. GUPTA: (Off mic.)

8 MR. RIVEST: But we're talking about the LCC

9 here.

MR. BROOKMAN: Repeat that for the record,

11 please. Mimi, get up here. Say what the presumption

12 is again, please, Mimi?

13 MR. RIVEST: We're reacting to which?

14 MS. GUPTA: Right. So for four­foot medium

bi­pin and eight­foot single­pin slimline lamps, we

16 assume that the installed base is magnetic for T12

17 lamps and that purchases will be electronic. For HO

18 lamps, given the information from the 2000 ballast

19 rule, we assumed that the installed base of high

outputs were electronic.

21 MR. HOWLEY: That would be incorrect.

22 MS. GUPTA: Okay. All right. So if you have

23 any information about, like, the markets you have

24 magnetic and electronic in the high output market ­­

MR. HOWLEY: Well, for years the T8 high

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1 output was only sold on magnetic. The electronic came

2 in relatively recently in that particular product

3 category. Probably within the last five years or so.

4 But the vast majority of those products, baseline would

be electromagnetic.

6 MR. BROOKMAN: Please. Come to the

7 microphone and say your name for the record, please.

8 DOE welcomes any additional data here.

9 MS. ANDERSON: Susan Anderson with Osram

Sylvania. The other point is that one of the big

11 exceptions in the ballast rule is for the magnetic

12 minus 20 degree HO ballast, which is a very large

13 application for T12 HO lamps. So you're going to

14 continue to see those sold. Even new shipments will be

magnetic.

16 MR. BROOKMAN: I see. So, going back to you,

17 could you hazard a guess about how much of the

18 installed base is magnetic?

19 MS. ANDERSON: Ninety­nine.

MR. BROOKMAN: Ninety­nine?

21 MR. HOWLEY: A very high percentage would be

22 magnetic.

23 PARTICIPANT: It's only been in the last

24 couple years we even had an electronic T12 ballast.

MR. BROOKMAN: Okay. So thanks for that ­­

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1 thanks to all of you for that data. Gary.

2 MR. FERNSTROM: So, Gary Fernstrom, PG&E.

3 I'd just like to ask whether this is a marginal

4 analysis or an average or embedded analysis. You know,

for sure Joe is right, the majority of equipment out

6 there is magnetic now, but are we looking at the

7 embedded or should we be looking at current shipments.

8 MR. BROOKMAN: Yeah, yeah.

9 MR. HOWLEY: I think the rulemaking, though,

that she's pointing to didn't include a basic ballast

11 type because for whatever reason that rulemaking had

12 that product exempted. So it sounds like that

13 rulemaking simply missed or did not have that included.

14 So that's why you missed that entire product category.

MR. BROOKMAN: I'm not sure you heard Gary's

16 last question, which was about whether this analysis

17 should focus on the installed base or prospective

18 sales.

19 MS. GUPTA: I think we're looking at both

here. The national impact analysis is very dependent

21 on the installed base, and the LCC analysis is more

22 dependent on sales. But to some extent, it's dependent

23 on the systems that are installed right now because

24 when examining a lamp replacement, you have to take

into account what ballasts exist at that time.

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1 MR. BROOKMAN: Mike Rivest.

2 MR. RIVEST: I guess the one missing piece of

3 information for me is, is the magnetic ballast for

4 those systems going to be sold after the standard is in

place? They continue to exist.

6 MR. BROOKMAN: Pam, go ahead.

7 MS. HORNER: 2011. Isn't that the last year?

8 MS. ANDERSON: Yes, but ­­

9 MS. HORNER: For replacement.

MR. BROOKMAN: So, 2011, and then to ­­ is it

11 Susan?

12 MS. ANDERSON: But one of the exceptions to

13 the ballast rule is the minus 20 degree magnetic

14 ballast for T12 HO. That's one of the largest markets

for T12 HO. So magnetic ballasts will continue to be

16 sold.

17 MS. HORNER: In that category.

18 MR. RIVEST: Okay. So there should be two

19 baselines.

MR. BROOKMAN: Yes, please. Pam.

21 MS. HORNER: Pam Horner, NEMA. Since we're

22 talking about electronic versus magnetic and this

23 slide, I think you would be well served to ­­ do you

24 see under four­foot, which is the first bullet. Under

that is baseline. And then what you have is T12

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1 systems, magnetic ballast or an electronic ballast.

2 Could you ­­ how can you have ­­ is that two baselines?

3 Because, again, taking the consideration we're talking

4 about that you're going to do installed base,

personally I can't even imagine a four­foot electronic

6 T12 being anything.

7 MR. BROOKMAN: Mimi.

8 MS. GUPTA: I think the answer to a lot of

9 these questions will become clearer when we talk about

the life­cycle cost analysis. The idea is that we have

11 one T12 ­­ for each baseline T12 lamp we might consider

12 the purchase of a new electronic ballast for new

13 construction.

14 I mean, I think these questions will become

more clear when we talk about how we structured the LCC

16 analysis, but we recognize in our analysis that most

17 T12 systems do have a magnetic ballast associated with

18 them.

19 MR. BROOKMAN: Do you recognize their

assertion that it's very, very small? One percent is,

21 I believe, what they said.

22 MS. GUPTA: Yeah. I mean, that's ­­

23 MR. BROOKMAN: Okay.

24 MS. GUPTA: We definitely recognize that for

four­foot and eight­foot slimline in the analysis right

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1 now, and we appreciate your comments regarding the high

2 output.

3 MR. BROOKMAN: Let's get any other comments

4 on this and then we'll hold off on the larger question

until we get to life­cycle cost. Go ahead. Then I'm

6 coming back to you.

7 MR. WALITSKY: Paul Walitsky, Industrial

8 Ecology. I just wanted to raise one issue on the

9 ballast. The voltage, 120 versus 277. Because there's

a difference in the efficiency on a universal ballast

11 that will cover 120 to 277 versus the individual. I

12 don't know what you took ­­ I presume you used 120

13 voltage, but I don't know. I think that would be worth

14 looking at as well.

MR. BROOKMAN: Do you know that?

16 MR. O'ROURKE: I'm not sure for this rule

17 here. I know that in an unrelated rule on ballasts

18 that is being taken into account. But for this I think

19 ­­ I'm not sure if there was a specific 120 or only

277. It might have just been selecting particular

21 systems in that case. But, thank you for that comment.

22 MR. BROOKMAN: Okay. Keith, go ahead.

23 MR. COOK: Keith Cook, Philips. Could we go

24 back to Slide 24 for just a second? I guess one

question I've got here is the baseline that was chosen

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1 was always the minimum CRI for each class and it was

2 also the minimum lumens per watt for each class. So,

3 as a result, aren't we going to be led a little bit

4 astray from the fact that those are probably also the

lowest cost? And so when we look at total payback it

6 will be the most favorable when we do the comparison?

7 MR. O'ROURKE: Again, Mimi will be talking

8 about that when she does the LCC, but we're starting

9 out where the bottom of ­­ the lowest­performing

products are today. I mean, there already is an

11 existing energy standard in place that's even lower

12 than that. We're raising that bar up to where the

13 bottom of what's on the market today is and then seeing

14 how high above that you can go.

But the economic impact will be taken into

16 account, whether how much more expensive it is or that

17 you need to switch ballasts. That is taken into

18 account in the LCC, and she will go through that.

19 MR. BROOKMAN: Mike Rivest and then back to

Steve.

21 MR. RIVEST: What you said is correct. In

22 the LCC, we calculate the full life­cycle cost of every

23 lamp. So everything is referenced back to the least

24 efficient lamp when you look at the results. If you

want to compare, say, Lamp Number 5 with Lamp Number 4,

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1 you would subtract the LCC of Lamp Number 5 from Lamp

2 Number 4.

3 If we had perfect information, we would know

4 the distribution of sales by efficacy, and then we

could provide you with the LCC for the distribution of

6 lamps is this much, for the whole class. But we don't

7 ­­ we barely have data separating out the 700 and 800

8 series. We certainly don't have data that would break

9 down 700 series into subgroups like that.

MR. BROOKMAN: Steve Nadel.

11 MR. RIVEST: In the national energy savings

12 model, however, we have a full matrix which we've

13 populated with assumptions about the market share of

14 each lamp­ballast combination and we calculate the full

energy savings over time based on that. When we talk

16 about it later, that's critical data that we need to

17 calculate the energy savings. So we'd be looking for

18 some guidance as to, you know, what weights to put onto

19 each of those ballast­lamp combinations.

MR. BROOKMAN: Steve Nadel.

21 MR. NADEL: Mike just said most of what I was

22 going to say. The national energy saving economic

23 analysis is critical. So if one combination has only a

24 one percent market share, it will only get a one

percent weighting and the more common ones will

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1 dominate.

2 MR. BROOKMAN: Andrew, yes.

3 MR. DELASKI: Yeah. Mike, I wonder if you

4 could circle back to, then, you discussed about what

the baseline ­­ how it differs as you consider it for

6 the NIA and for the LCC. But then, what then ­­ if you

7 come back to the slide in front of us, which is ­­ in

8 front of me is Slide 28.

9 MR. O'ROURKE: Do you want to go to 28?

MR. RIVEST: Yeah.

11 MR. DELASKI: What are you trying to capture

12 with the baseline in this slide? What is the baseline

13 you're trying to show in the engineering analysis?

14 MR. RIVEST: All right. In the engineering

and the LCC what we're trying to determine is, in the

16 absence of a standard, what are the possibilities of

17 technologies that a consumer would select. Now, the

18 truth is ­­ and Mimi corrected me. I had my head on

19 wrong ­­ the ballasts are in place in 2012, the first

year of the standard. Therefore there are both people

21 with magnetic ballasts and some minute amount of people

22 with electronic T12s.

23 We're capturing the impacts on both of those

24 scenarios. So we call them both baselines because

that's a starting point for some people.

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1 MR. DELASKI: It's a stock baseline.

2 MR. RIVEST: It's a stock for ballasts, but

3 sales of the lamps are still feeding a certain ballast

4 which is in the stock. So that's where I was myself

getting confused.

6 MR. BROOKMAN: Mimi.

7 MS. GUPTA: Yeah, Mimi Gupta. So the

8 magnetic ballast represents a stock baseline for T12s.

9 The electronic ballast represents a shipment baseline

for T12s.

11 So if you were wanting to look at what are

12 the economic impacts of just replacing a lamp on an

13 existing system, then you assume that system has a

14 magnetic ballast. If you wanted to look at the impacts

of buying a whole new system, then you would assume

16 that that person would have bought an electronic system

17 because they can't buy a magnetic ballast anymore.

18 Does that make it at all clear?

19 MR. DELASKI: (Off mic.)

MS. GUPTA: Excuse me?

21 PARTICIPANT: No, they're not right now,

22 because ­­

23 MS. GUPTA: But in 2012, because of the

24 ballast rulemaking, magnetic ballasts for four­foot

medium bi­pins won't be available.

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1 MR. BROOKMAN: Joe, go ahead. Joe, go.

2 MR. HOWLEY: Except one exception. The high

3 output magnetic ballasts. Again, kind of what we

4 missed here. They only regulated that from a low

baseline, basically an aluminum wire electromagnetic,

6 up to a high efficiency electromagnetic. So in that

7 case, that ballast will actually continue to exist,

8 which is why it's such a glaring missing component

9 here.

MR. RIVEST: We're with you on that one.

11 MR. BROOKMAN: Have we resolved this? I

12 think so. Okay. So, keep going.

13 MR. O'ROURKE: On Slide 30, we're showing a

14 table at least of the proposed candidate standard

levels, as to the columns there on the left, and

16 showing the associated efficacies with each candidate

17 standard level. There's also columns for the different

18 lamp types of T12, the 40­watt T12, the 34­watt T12,

19 and the 32­watt T8.

These would be the two baseline levels for

21 the T12s, the first row. And down here at the 700

22 series for Candidate Standard Level 2, that would be

23 the lowest candidate standard level baseline for the T8

24 system.

As I mentioned before this slide was that at

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1 Candidate Standard Level 4 and 5 you start having that

2 only T8s can meet those higher candidate standard

3 levels.

4 As you progress down a given slide for a

given lamp type, you see the overall improvements are

6 happening through better phosphors but also other

7 improvements to the lamp that could gain those higher

8 efficacies with given phosphors. So we've named them:

9 the 700 series, improved 700 series; 800 series and

improved 800 series.

11 Any questions on this table?

12 (No response.)

13 MR. O'ROURKE: Okay. Thank you. So we're

14 going to start now talking about how these relate to

each one of the categories. Here is a four­foot medium

16 bi­pin, again showing a similar graph to what I showed

17 you before with the arrows on it, the yellow and green

18 arrows.

19 For now, we're showing where ­­ start off

with where the baselines are again for the 40­watt T12,

21 the 34­watt T12, and over to the 32­watt T8. The red

22 lines drawn here are showing the different candidate

23 standard levels. So CSL 1 is a little over 82, CSL 2

24 is about 85 lumens per watt, and up to 90 lumens per

watt for CSL 3, and a little above 92 for CSL 4, and

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1 lastly, CSL 5 at a little over 95.

2 As you get up to these higher, the CSL 4 and

3 5, there are no longer any T12 lamps that would be able

4 to have a high enough efficacy to meet those

requirements. Questions?

6 MR. BROOKMAN: Keith.

7 MR. COOK: Keith Cook. When you established

8 these candidate standard levels, were these supposed to

9 be minimum values or nominal values?

MR. O'ROURKE: These were minimum, to be

11 within a given candidate standard level.

12 MR. COOK: That may end up being a problem

13 because it's based upon nominal value products, so.

14 MR. O'ROURKE: Yes.

MR. BROOKMAN: Mimi.

16 MS. GUPTA: I'm not sure if I totally

17 understand your question, but the candidate standard

18 levels were based on rated lamp efficacies, not the

19 nominal lamp efficacy. Is that what you were referring

to?

21 MR. O'ROURKE: The comment is the rating is

22 not a precise number. It has some tolerance about that

23 number, and some of those same ­­

24 MR. COOK: Manufacturing tolerances that make

it a plus or minus, and typically those are ­­

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1 MR. BROOKMAN: Steve Nadel.

2 MR. NADEL: Yeah. Did DOE get data on actual

3 lumens per watt as opposed to just doing the

4 calculations from a catalogue? As I remember when we

first developed the EPACT '92 standards, we did get

6 some data and we looked at actual product rather than

7 just assuming it's all 48 or 34 or whatever.

8 MR. O'ROURKE: This is based on catalogue

9 data. The only exception is the wattages, where

appropriate, we're using the ANSI wattages of the lamp,

11 not the rated watts. For example, the 32­watt T8 ANSI

12 wattage is 32.5 watts. So we used the wattages for the

13 appropriate lamps that were listed in ANSI.

14 MR. BROOKMAN: Can you say generally how much

the variance is?

16 MR. COOK: It depends upon what the

17 particular criteria is. It varies. Probably by

18 manufacturer, too, because depending upon the processes

19 used in manufacturing itself.

MR. BROOKMAN: That was Keith. Yes, Joe.

21 MR. HOWLEY: Just to note here, there were

22 reporting requirements for the 1992 law. So there is

23 actual test reports on file with the DOE, and it may be

24 good to look at some of the actual reported data versus

the nominal or catalogue­rated data to get an idea if

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1 these are practical or not based on the actual testing

2 of those lamps.

3 MR. BROOKMAN: Thank you. Thanks for that.

4 Tom Eckman.

MR. ECKMAN: Tom Eckman, Northwest Power and

6 Conservation Council. Since the analysis is an

7 incremental analysis, the real question is whether or

8 not there's a bias as you go up, whether the tolerance

9 band changes as you go up at each of these increments,

because you're looking at the prices of those and

11 whether or not this is a good representative of the

12 mean of each of those increments.

13 MR. RIVEST: I don't think the incremental

14 aspect of the analysis would be affected, but it might

be a question of then setting the standard, and a

16 standard that would be representative of those lamp

17 series.

18 MR. ECKMAN: I'm fine with going to the

19 tests. I think that's appropriate. But in terms of

whether there's a bias in this ­­

21 MR. RIVEST: No, I don't think so.

22 MR. LEWIS: Doug.

23 MR. BROOKMAN: Yes, Ron Lewis.

24 MR. LEWIS: To Joe's point, in the reporting

by lamp manufacturers, I believe that in the EPACT '92

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1 there was a tolerance given that was allowable, that

2 you had to certify that you were within that tolerance.

3 And it was a rolling average over 12 years of

4 production or something.

PARTICIPANT: Twelve months.

6 (Laughter.)

7 MR. LEWIS: The report said 12 years.

8 MR. BROOKMAN: Hoping for the best, right?

9 (Laughter.)

MR. LEWIS: But it was already defined as

11 what the allowable tolerance was there. I remember

12 there was a lot of discussion over what that should be

13 and what the manufacturing tolerances were and the

14 reality factor versus just a rated. So I think that's

already ­­

16 MR. O'ROURKE: That's correct.

17 MR. LEWIS: ­­ described, what the allowable

18 manufacturing tolerance was. So maybe we can even take

19 that into account. If you've lived with that since

1992 and have been certifying to that, there's probably

21 a hard number there of what a meaningful tolerance is,

22 rather than going through every piece of data since

23 that time.

24 MR. O'ROURKE: Right. An additional comment

to that is that that data would only be for lamps that

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1 would have been covered at that time. It's not going

2 to be covering the lamps at the upper end here because

3 those lamps were not covered products at the time.

4 MR. HOWLEY: Right. But it will give you

some sense of the lower end of where things are at.

6 MR. BROOKMAN: The last comment from Conan

7 and then back to Joe. Okay. So now, then, any

8 additional comments? We're still on 31, as I recall.

9 (No response.)

MR. O'ROURKE: Going on to the eight­foot,

11 single­pin, slimline candidate standard levels, again

12 showing Candidate Standard Levels 1 through 5, with

13 zero representing at least the baseline product for the

14 75­watt system. The baseline for the 60­watt system is

at Candidate Standard Level 1, and the baseline 59­watt

16 is at Candidate Standard Level 3. Once you get to 4

17 and 5, again, there's no T12 system that can meet the

18 higher efficacy for those candidate standard levels.

19 The columns again show the progression of the

technology or design options to get those higher

21 efficacies.

22 Any questions on Slide 32?

23 (No response.)

24 MR. O'ROURKE: So the associated graph that

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1 foot. You see the baselines for the 75­watt T12, then

2 the 60­watt T12, and the 59­watt T8. There's not as

3 much product available in these categories, so there's

4 a lot less dots to plot here. But there are some lower

wattage options at 59­watt ­­ at 57 watts as well.

6 Any comments on this slide?

7 (No response.)

8 MR. O'ROURKE: Okay. Continuing on to the

9 eight­foot, recessed, double­contact. This is, again,

covering the 110­watt T12 and the 95­watt T12. We're

11 not including a baseline lamp for the T8, but it is

12 included in the analysis. It's being included in the

13 analysis for the higher candidate standard level cases.

14 At Candidate Standard Level 2, at about 86

lumens per watt, the 110­watt lamp starts to fall out,

16 and at Candidate Standard Level 4 the 95­watt T12 lamp

17 falls out.

18 Any questions on this table?

19 (No response.)

MR. O'ROURKE: Okay. Lastly, the slide that

21 goes along with that showing the candidate standard

22 levels and the products, at least we found in the

23 catalogue. We didn't find any energy­saving versions

24 of the T8, so they're all within the same ­­ to take

advantage of those wattages, you'd have to use lower

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1 ballast factor ballasts to maintain light output. And,

2 you have the 95 as energy­saving to the 110.

3 Okay. So, an example of what the ­­ did you

4 have a question, Mike? Okay. Going on to the next

slide, showing the systems results, we're taking ­­

6 I've showed you the candidate standard levels for

7 lamps. I've described how we're going to take those

8 information for lamps and combine it with different

9 ballasts to create systems. This is just showing an

example of some of the results.

11 As Mimi mentioned, one scenario we're looking

12 at is if it's just a lamp replacement only. If you're

13 going, say, from a baseline product here to something

14 that has a higher efficacy ­­ so you take the 40­watt

T12 in the first row and you replace it on the same

16 system, same ballast, with a 34­watt, what is the

17 overall result. You can see that efficacy of the rated

18 lamp goes from 80 to 91.2.

19 Using ­­ actually, in this case we are using

a lowest ballast factor ballast, and we're looking at

21 the overall system mean lumens. Trying to keep them

22 approximate. There wasn't an attempt here to make them

23 identical. They're trying to stay within roughly 10

24 percent of what the baseline condition is.

Also, showing the other conditions. Here's a

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1 T8 system and its baseline. You would be able to look

2 at changing to other technologies and seeing how

3 efficacy is impacted as well as different systems that

4 may be used. In this case, these are electronic

systems that could be compared to any of these

6 baselines to look at incremental change and the overall

7 impact on what the system mean light output would be

8 based on using those systems.

9 Any questions on this example?

(No response.)

11 MR. O'ROURKE: I see some looks. I just want

12 to make sure. Okay. Yes?

13 MR. HARRIS: Jeff Harris of Alliance. Within

14 what range do you consider the light output to be

equivalent?

16 MR. O'ROURKE: We were trying to keep them

17 within about 10 percent of what the baseline system

18 would provide.

19 Okay. So now we're looking for comments on

the selection of lamp ballast designs for the baseline

21 to max tech as well as the selection of the general

22 service fluorescent lamp candidate standard levels.

23 MR. BROOKMAN: So the relevant feature here

24 being the baseline to max tech, or at least that being

one relevant feature. Please, Pam.

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1 MS. HORNER: Pam Horner, NEMA Lamp Section.

2 We'd like to make a comment to give you a little bit of

3 insight into a manufacturer's mind and how we look at

4 the candidate standard levels, which is a bit ­­ it's

in addition to the energy savings potentials. I think

6 you can appreciate that we also have begun to look at

7 these in terms of what products would no longer qualify

8 and which products would remain in the market.

9 So for the record, and for your

entertainment, I thought it would be interesting for

11 you for me to give a very brief summary of those

12 products. It won't take long, but it will then maybe

13 make sense as to what we have to say about that.

14 So the proposed CSL 1 for fluorescent, which

right now is numbers. Our analysis shows that this

16 would eliminate halophosphor T12s. Think about this as

17 manufacturing also, okay, because we have to do that.

18 That's what we're paid to do here, right, today? While

19 continuing to allow 34­watt T12 700 series ­­ that's

your energy­saver type ­­ and your 40­watt T12 7­ and

21 800 series. So there would be some T12s in the market

22 and all T8 would comply.

23 MR. BROOKMAN: Do you want to follow on

24 briefly? Use the microphone.

MS. GUPTA: Could you go to Slide 30, Conan?

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1 MR. RIVEST: Actually, could you go to the

2 slide with the bars?

3 MS. HORNER: Don't you think that's hard to

4 read?

MR. RIVEST: Okay. Well, the other one.

6 (Laughter.)

7 MS. GUPTA: This is what, I guess, you would

8 be validating ­­

9 MS. HORNER: Those are design options. Pam

Horner again. If a design option is what I'm

11 describing now, then ­­ I don't think so.

12 MR. NADEL: I think they are the same, but

13 you should check Candidate Standard Level 3 or

14 something just to make sure it pretty much includes ­­

MS. HORNER: For example, Candidate Standard

16 3. What we see is that it would allow the 34­watt and

17 40­watt T12 enhanced 800. It's not just the 800.

18 MR. O'ROURKE: What we call "improved."

19 MS. HORNER: Yeah. Okay. And as we move

along, then we'd have ­­ at 4 we would eliminate T12.

21 Okay. And at 5, all we'd be left with in the market

22 would be 32­watt, 28­watt, and 25­watt highly improved

23 800 series. Does that correspond?

24 MR. O'ROURKE: Yeah.

MS. HORNER: Okay. So what our mindset is,

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1 is that we would not only look at is this good for

2 energy savings but how do manufacturers change what

3 they do for a living, change over the lines, et cetera.

4 So you will know that our comments are going to have

to include what the impact upon us would be. We're not

6 ready today to say what that will be, but it certainly

7 will be in our written comments.

8 The other issue is that we need a little bit

9 of time to understand how ­­ if these are a reasonable

fit with the timing of the ballast rule. So, in other

11 words, as an example, if people are still allowed to

12 buy ballasts December 31st, 2010, or sometime in 2011,

13 that are magnetic for use, say, in their homes for T12

14 type lamps, in our minds is it reasonable to expect

that they should have some life out of those.

16 In other words, is it incumbent upon us as

17 lamp manufacturers to be able to provide lamps to them

18 for their newly purchased ballasts. To me, that's a ­­

19 I don't know how you can characterize that solely as a

number. You know, what is the obligation of an

21 industry like ours to be able to continue to provide

22 lamps.

23 I'm not saying we are saying together, oh,

24 let's pick Number 3. But those are the sorts of things

that run through a manufacturer's mind beyond the

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1 numbers, so I wanted to express that.

2 MR. BROOKMAN: Okay. Thank you. Thanks for

3 that illustration. Joe, please.

4 MR. HOWLEY: Joe. Also, I just wanted to

comment that within the efficacy numbers I think our

6 technical people are still looking at these numbers

7 based on actual test data to see if those indeed would

8 be the numbers we would suggest. We understand what

9 the objective is. We see that in the design options

for each ballast. But I know that we're looking at

11 those objectives versus those numbers and may have some

12 further comments on whether or not we feel those

13 numbers are the right numbers to hit those objectives.

14 So perhaps we'll have further clarifying

information in our written comments as well on that.

16 MR. BROOKMAN: Thank you. Okay. So, Conan,

17 take us back to where we were.

18 MR. O'ROURKE: On Slide 37?

19 MR. BROOKMAN: Yes.

MR. O'ROURKE: Any more ­­

21 MR. BROOKMAN: So, final comments before we

22 move on to Slide 38?

23 (No response.)

24 MR. BROOKMAN: Okay.

MR. O'ROURKE: In Slide 38, we're now looking

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1 at scaling to the other product classes that weren't

2 directly analyzed. So, looking at scaling from less

3 than 4,500 up to above 4,500, we looked at the products

4 that were on the market and we looked at the 6,500 K

and saw that they were approximately four to seven

6 percent lower than the 4,100 K.

7 So to avoid overly penalizing the current

8 products offered on the market, we considered adopting

9 the larger of the two scales as how much it could be

reduced by to seven percent. For example, if the

11 requirement was 82.4 lumens per watt for the four­foot

12 medium bi­pin of less than 4,500, if we picked one that

13 was greater than the requirement, it would be 76.6

14 lumens per watt.

Scaling to the other product classes for the

16 two­foot U­shaped lamp, we looked again at ­­ these are

17 ones less than 4,500. The efficacy differentials were

18 approximately three to six percent. Again, the similar

19 fashion of looking at the range. We used a maximum

allowed to six percent to do the scaling for these

21 products.

22 So the Department invites comments on these

23 methods used to scale products for above 4,500 and also

24 for the U­shaped.

MR. BROOKMAN: Steve Nadel.

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1 MR. NADEL: I was just curious if anybody,

2 either DOE or the manufacturers, have rough data on how

3 large a share of the market U­shaped are. Are they

4 pretty small these days?

MR. HOWLEY: Relatively.

6 MR. NADEL: I know they were big in the '90s,

7 but I haven't seen them that much since then.

8 MR. BROOKMAN: Joe.

9 MR. HOWLEY: This is Joe Howley. There's

been less and less use of the U shape. People seem to

11 be going more towards, if they want a two­by­two

12 fixture, even a two­foot T8 versus the U lamp. So

13 we're seeing that kind of fall out of favor somewhat.

14 Or what we call the high­lumen bi­ax. There's other

names as well.

16 (Laughter.)

17 MR. BROOKMAN: Thank you. So then,

18 additional comments on scaling?

19 (No response.)

MR. O'ROURKE: All righty. Moving on from

21 fluorescent to incandescent reflector lamps, going back

22 to baseline models, the Department has identified three

23 common lumen packages that represent the typical lamps

24 on the market for the standard spectrum incandescent

reflector lamps. These lamps are currently regulated

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1 and would meet the requirements of the EPCA standard.

2 We're showing here on the table PAR 30s and

3 PAR 38 halogen lamps at 50, 75, and 90 watts with these

4 appropriate efficacies, 11.6, 14.0, and 14.6, and these

initial light outputs of 580, 1,050, and 1,310, and

6 associated lifetimes for those lamps.

7 Looking at substitutes for those lamps, the

8 Department chose substitutes to save energy and achieve

9 similar light output by increasing either the efficacy

or using a reduced wattage option. For example, using

11 a 50­watt ­­ looking at a 44­watt replacement to a 50­

12 watt lamp.

13 Wherever we could, we used commercially

14 available information, and in some cases we weren't

able to. We used modeling to help identify what those

16 would be.

17 And the ones that we ­­ the three basic

18 design options associated with the commercially

19 available ones were improved halogen, halogen infrared,

and improved halogen infrared. Those different

21 technologies also had the implication on lifetime of

22 3,000 hours or 4,000 hours.

23 The improved halogen and improved halogen IR

24 could be achieved using higher efficiency filaments,

filament coiling, filament configuration, capsule

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1 design, higher pressure, or higher efficient reflector

2 coating.

3 As I mentioned for modeling, we used

4 commercially available lamps wherever we could but when

we couldn't we ­­ based on manufacturer's interviews

6 and technical literature, we ­­ used to develop models.

7 The model lamps that we used were these particular

8 ones of 14 lumens per watt, which would give you 44.3

9 watts for PAR 30. That would be a reduced wattage

equivalent of a 50­watt lamp. A 15 lumens­per­watt PAR

11 30, which could also be compared to the 50­watt lamp,

12 and a 66­watt, 19.8 lumens­per­watt PAR 38, which would

13 be a reduced wattage of a 90­watt.

14 So, looking at this graph, we're seeing

different lamp powers and we're seeing the different

16 baselines of the PAR 30 50­watt, PAR 38 75­watt, and

17 the PAR 38 90­watt. We're seeing that as you increase

18 the efficacies, then we have a shift in lower wattages

19 for those given technologies.

So the Department would invite comment on the

21 selection of the IRL designs from the baseline to the

22 max tech.

23 MR. BROOKMAN: Pam.

24 MS. HORNER: Pam Horner, NEMA Lamp Section.

Regarding the baseline, let me get this straight. For

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1 this category you have selected a halogen lamp ­­

2 MS. GUPTA: Yes.

3 MS. HORNER: ­­ as the baseline, not the BR30

4 or the BR40, even though the installed base and the

exemptions for those remain in place.

6 MR. BROOKMAN: Would you offer a different

7 rationale for ­­ would you say more about ­­

8 MS. HORNER: I will get to that when he asks

9 the next question. I just wanted to make certain. I'm

building. Just as you are building your case, Conan, I

11 am building my rebuttal.

12 (Laughter.)

13 MS. HORNER: So I have understood that

14 correctly.

MR. BROOKMAN: Mimi.

16 (Laughter.)

17 MR. FERNSTROM: Pam, this is Gary from PG&E.

18 It's kind of hard to get this straight because that's

19 a curved lineup there.

MS. HORNER: I think that was a joke.

21 (Laughter.)

22 MS. GUPTA: Yes. We choose the halogen

23 technology as our baseline because even though EISA

24 2007 brought in BR and ER lamps, those will have to

meet the standard by the time 2012 comes around.

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1 MS. HORNER: Except for the exempted types.

2 MS. GUPTA: Except for the exempted types,

3 which this rulemaking doesn't cover, either.

4 MR. BROOKMAN: That's the key point, right?

MS. GUPTA: Right. Any incandescent

6 technology IRLS this rulemaking does not cover.

7 MS. HORNER: Oh, I understand that.

8 MR. BROOKMAN: Do you want to let ­­ do you

9 want to keep going or do you want to let ­­

MS. HORNER: Yes, I have one more sentence.

11 MR. BROOKMAN: Keep going. No, we want you

12 to develop fully your ­­

13 MS. HORNER: Yes.

14 MR. BROOKMAN: ­­ your rebuttal.

MS. HORNER: So the other sentence, then, is

16 that in that case, another ­­ shall I just put it this

17 way. Another way of looking at this is that since the

18 BR conundrum has entered and exited, and entered and

19 exited our lives throughout the world since 1992, it

would appear that BR has been cast aside to a safe

21 haven and now the DOE is looking at what they consider

22 to be remaining, and then from that remaining group has

23 selected something which they are considering a

24 baseline above which they would like to raise the bar.

Do I have that correct?

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1 MR. RIVEST: Yes.

2 MR. BROOKMAN: Mike Rivest. Yes.

3 MS. HORNER: Fine. Then, when you come to

4 your next set of questions, I will comment. Thank you.

MR. BROOKMAN: Steve Nadel.

6 MR. NADEL: Just anticipating ­­

7 MR. BROOKMAN: Wait a second. The suspense

8 is building here.

9 (Laughter.)

MR. BROOKMAN: Keep going, Steve.

11 MR. NADEL: Right.

12 MR. BROOKMAN: Anticipating, you said.

13 MR. NADEL: Because this rulemaking is not

14 looking at the 65 BRs, they're looking at alternatives

to those, but as I recall from reading the ANOPR, in

16 the national energy­saving model they do consider how

17 people will switch from these products to BRs. So

18 that's the place where I believe the case you're trying

19 to make may play out.

MR. BROOKMAN: Anticipating as you might.

21 MR. NADEL: Foreshadowing.

22 MR. BROOKMAN: There you go. Okay. So then,

23 back to you, Conan, if I'm not mistaken.

24 MR. O'ROURKE: No more comments on this?

We'll go now to discuss what the candidate standard

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1 levels would look like for those products.

2 This was basically used to develop a

3 continuous equation to set the minimum efficacies

4 across these wattages. And the equations are shown in

this table for CSL 1. It's basically parallel varying

6 the constant in front of each one of them as you go to

7 the higher and higher candidate standard levels. They

8 would represent the design options, going from improved

9 halogen, to halogen IR, to improved halogen IR.

So here, Pam, to show where you were asking

11 about, where the baselines are representative to the

12 existing EPCA requirement today and where they fall

13 relative to those, and showing what the new CSLs would

14 ­­ CSL 1 and CSL 2 and CSL 3 for each of those

different design options.

16 So, the Department invites comments on

17 whether the IRL candidate standard levels represent the

18 appropriate technology across all wattages.

19 MR. BROOKMAN: Pam.

MS. HORNER: You anticipated. Pam Horner,

21 NEMA. So, first of all, regarding the formulas, again

22 we like the smoothing. That's a very good idea. And

23 not using a step function. But we would like to

24 comment, and will certainly comment in writing even

more, about these models.

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1 The lamp upon which CSL 1 is based ­­ did

2 everyone hear that?

3 (Laughter.)

4 MS. HORNER: ­­ shows a strong resemblance to

a known silver­coated PAR 38 halogen reflector lamp for

6 which only one company holds the patent, and the lamp

7 manufacturer that holds that patent is a NEMA member

8 and does approve of my going onward with this comment.

9 If this is the case, which we believe it is

because we do have the catalogue sheet upon which all

11 of these curves were based, then it would be, shall we

12 say, problematic for any other manufacturer to meet

13 that level. Since silver is the most efficient

14 reflector, no other materials can achieve this

reflectivity to our knowledge. So the one manufacturer

16 that is holding the patent has held the high ground.

17 So to establish a level that is an attempt to

18 improve the efficacy above a "standard" PAR 38 halogen

19 lamp has just made a one­manufacturer world. You may

not have known that.

21 CSL 2, which is based upon IR­coated halogen

22 capsules, appears to correspond very, very well with

23 products from many manufacturers in the market. One

24 could consider CSL 2 to be a level playing field.

There are other arguments against it, but it does have

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1 that.

2 Now when you move to CSL 3, the same patent

3 issue applies because the improved reflector material

4 which has been used to create these formulas and those

lines is the silver­coated reflector.

6 The other comment that we would like to make

7 regarding these formulas regards something that you

8 have not included in your analyses, and that is lamp

9 diameter. The LPW formulas appear to apply to all

covered lamp diameters because there is nothing that

11 says otherwise. With the enactment of EISA, as we

12 discussed this morning, PAR 20 lamps are now covered.

13 We just established that the 40­watt through 205­watt

14 range is what is covered.

PAR 20 lamp optical systems are less

16 efficient than those of PAR 30 and PAR 38 by a

17 significant percentage. It's simply a matter of

18 geometry and size.

19 In our written comments we're going to

recommend that some percent reduction factor be applied

21 to these CSLs in order to account for that difference.

22 We have something in mind but have not settled on such

23 a percentage.

24 The other point I would like to make is that

if that is not done, all 50­watt PAR 20 lamps have just

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1 been wiped out.
 

2 MR. BROOKMAN: Ron Lewis.
 

3 MR. LEWIS: If I could move us back to Slide
 

4	 41.

MR. BROOKMAN: Is this the CFL ­­ is this the

6 equivalent of CSI here.

7 (Laughter.)

8 MR. LEWIS: The last bullet point, where it's

9 stated that there are different ways of meeting the

improved halogen and improved HIR with design options.

11 From what you're saying, is for two of those there is

12 only one way to meet those? None of these other

13 factors are options, whether they're in play right now

14 or not?

MR. BROOKMAN: Yeah, Pam. Please.

16 (Laughter.)

17 MS. HORNER: I'm waiting for permission.

18 What we're saying is that the most effective way of

19 improving the efficacy, and in fact the very line

that's been chosen was based upon that particular

21 technology. To use gas to do it won't get there. To

22 use a different material other than silver won't get

23 there.

24 MR. BROOKMAN: Steve Nadel.

MR. NADEL: I'm just trying to read your

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1 parsing. To use other materials and the gas, will it

2 get you there?

3 (Laughter.)

4 MR. BROOKMAN: The and/or.

MS. HORNER: I can't answer that today, but

6 very specifically, I can't tell you, you know, some

7 magic combination of xenon or whatever. But I told you

8 the problems with xenon right now.

9 There are other problems, which I'm going to

introduce later, with this having to do with lamp life,

11 et cetera. But I'm saving that for the after­break.

12 (Laughter.)

13 MS. HORNER: But according to ­­ now I'm ­­

14 if I may switch, I'm switching hats. I'm not speaking

as a NEMA person. I'm speaking as an Osram Sylvania

16 person.

17 Our incandescent and halogen engineering

18 staff, which is a considerable sized group, has

19 indicated to us that because of this patent they cannot

make a lamp that violates that ­­ or, that doesn't

21 violate it, excuse me, and that they cannot reach it

22 with known technologies.

23 Now, of course you can jump to CSL 2, which

24 I've already explained. Now we're just talking

technologies, and I haven't mentioned anything about

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1 whether or not we think that's a good idea. All I'm

2 saying is that the facts are that the HIR level is the

3 level playing field. Easy for me to say.

4 MR. BROOKMAN: Okay. Andrew Delaski.

MR. DELASKI: When does the patent expire,

6 Pam?

7 (Laughter.)

8 MS. HORNER: I have a copy of it, but I don't

9 ­­ no, and it's a process patent, so it's not just the

application of silver to the reflector but it's also a

11 coating that prevents the silver from oxidizing both

12 during the manufacturing process and during use. I

13 don't know the expiration date of the patent.

14 MR. BROOKMAN: Joe, did you have a comment?

MR. HOWLEY: Just make one comment. I just

16 wanted to make it clear that it is not that the

17 manufacturers are supporting CSL 2. I'm not sure how

18 you interpreted Pam's comments, but that is not what we

19 are saying.

In fact, I think it's critical that we

21 provide consumers with options. The HIR technology

22 when you apply it to PAR lamps gets fairly expensive.

23 Although it might make sense for a retail application,

24 it probably does not make a lot of sense for consumer

applications. I think it's critical that we allow

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1 consumers to have a cost effective alternative to use

2 in their homes as well.

3 So I think there are issues with all three

4 approaches and that whole area may have to be

reconsidered in terms of the levels.

6 MR. BROOKMAN: Steve Nadel.

7 MR. NADEL: You mentioned consumer

8 applications. My understanding is the majority of

9 consumer applications are using the BR lamp and not

these other products.

11 MR. HOWLEY: Both are used.

12 MR. DELASKI: This is Andrew Delaski. The

13 Department, I think, has ­­ done a good job on the LCC.

14 Look at that ­­ we'll get to that later, but that's ­­

the option for the consumer includes 65­watt BR. A

16 person who wants to go to Home Depot and buy a 12­pack

17 for 20 bucks, it's still there.

18 MS. HORNER: This is Pam. Which means that

19 the BR could have been used as a baseline.

MR. BROOKMAN: Additional comments on this

21 subject?

22 (No response.)

23 MR. BROOKMAN: Okay. We've covered it

24 sufficiently? I think so.

MR. O'ROURKE: All right. Moving on to

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1 modified spectrum. Looking at trying to scale to

2 modified spectrum and coming from the standard spectrum

3 lamps, looking at the products on the market, you're

4 seeing roughly anywhere from two to almost 30 percent

reduction in efficacy. The average is about 15.

6 So the Department recognizes that this may

7 have some distinct utility, but we're looking for a way

8 to establish a standard that both does not eliminate

9 modified spectrum lamps, which require a low efficacy

standard because of their distinct utility, and

11 acknowledges the range of spectrum modifications

12 possible for these different IRLs and their

13 corresponding efficacies.

14 So I will say a ­­

MR. BROOKMAN: It looks like Gary ­­

16 MR. FERNSTROM: Gary Fernstrom,

17 a question. We talked earlier in the day

18 definition of the modified spectrum lamp.

19 and maybe some others said it. It had to

yellow light or ­­ by a certain number of

PG&E. Conan,

about the

I think Joe

filter out

macadam

21 circles from the black body of the radiation curve.

22 Does that definition apply to this entire ­­

23 to the 29 percent range so as to say that, you know, we

24 can do that much filtering for a two percent reduction

or the same amount for a 29 percent reduction?

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1 MR. O'ROURKE: We didn't have all the special

2 power distributions for these products, so we're trying

3 to base it on what they were marketing the product as

4 and how it performed.

MR. FERNSTROM: Okay. So just to be clear,

6 these products were marketed, that you looked at, as

7 modified spectrum lamps and therefore must have met the

8 definition.

9 MR. O'ROURKE: Well, they didn't necessarily

meet the definition because they're not necessarily at

11 this point compared to a clear lamp of the same exact

12 type to be able to look at that. Because it has a

13 requirement in there about how far it has to be from a

14 clear lamp with all the same technologies.

So we didn't have a clear lamp to compare it

16 to to see if it met that requirement. We're just

17 saying if you had the modified spectrum, what's its

18 efficacy compared to the best thing we could compare it

19 to to say how much it changed.

MR. BROOKMAN: Joe, go ahead.

21 MR. HOWLEY: I'd just like to comment that in

22 this particular market space right now there has been

23 no real definition of what one of these is. You have

24 manufacturers all over the board in terms of how

they're marketing them.

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1 But it's clear to us that something that only

2 provides a 2 percent reduction of lumens is not ­­

3 would never meet this kind of definition. It would

4 simply not be able to move the color point that far.

Somebody that just has an extremely light coating on a

6 lamp and it's a marketing game in that particular case,

7 that is not a product that would meet this definition.

8 Nor, in the marketing world today, there is

9 no definition. So you can market a lamp however you

want. But those lamps, although they may exist, would

11 not be able to meet that definition or exist under the

12 new regulations.

13 MR. FERNSTROM: Okay. Well, then I'm really

14 confused. Because if, in some respects, we're going to

exempt modified spectrum lamps or apply a different

16 standard to them, are we defining the extent to which

17 they modify the spectrum? Because if we don't, you

18 know, if you don't modify the spectrum very much, it

19 would be, you know, really easy to come in with what

appears to be a lamp that meets the requirements but is

21 pretty efficient.

22 MR. O'ROURKE: This is Conan again. One of

23 the requirements that they do to say how much they

24 change it is it has to be more than a four­step macadam

ellipse away from a clear lamp. So that's saying it

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1 has to change by that much. If it was within that, it

2 would be not a standard spectrum lamp.

3 MR. FERNSTROM: Thank you.

4 MR. BROOKMAN: Okay. Tom Eckman.

MR. ECKMAN: This data doesn't presume that

6 that's the case, the low end of that. I mean, you have

7 no idea ­­

8 MR. O'ROURKE: Correct.

9 MR. ECKMAN: ­­ two to 29 percent. You just

said ­­

11 MR. O'ROURKE: Correct.

12 MR. ECKMAN: ­­ it's indicative of whatever

13 is in the marketplace today, not the ones that actually

14 pass that test.

MR. O'ROURKE: That's correct.

16 MR. ECKMAN: So, you know, it's at best a

17 guess whether this is representative of what would pass

18 that test.

19 MR. BROOKMAN: Please.

MR. WALITSKY: Paul Walitsky. And then

21 what's going to happen is your average is going to go

22 up. If you illuminate the lower range ones, your

23 average in reduction may go to 20. I'm guessing. But

24 it's not going to stay at 15, which is, just

conveniently, the average between 2 and 29.

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1 MR. HOWLEY: That is correct. I agree with

2 Paul. Once you take all of the poor­performing lamps

3 out, you'll find the reduction in lumens from the lamps

4 that legitimately pass that definition would be higher.

It would probably be somewhere between 15 and 29

6 percent in actuality, not between two and 29 percent.

7 MR. BROOKMAN: That was Joe speaking. Tom,

8 do you have a follow­on comment?

9 MR. ECKMAN: If the criteria is the forced

macadam shift, then we ought to be representing that in

11 whatever offset there is. So to the extent that there

12 is some empirical basis for that which is a specific

13 test, it seems to me the data on that ought to be

14 looked at rather than just the catalogue data that

doesn't necessarily represent that.

16 MR. BROOKMAN: So, are there other comments

17 related to the other elements on Slide 46?

18 (No response.)

19 MR. BROOKMAN: No? Okay.

MR. O'ROURKE: Slide 47 is the last slide on

21 this topic and talks about a possible way to scale to

22 modified spectrum based on the light output of the

23 modified spectrum and the equivalent referenced clear

24 lamp, if you will, standard spectrum lamp.

So the reference standard would be equivalent

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1 to the modified spectrum, say, except for the neodymium

2 coating or other additive that caused the lamp to emit

3 that light. You would basically look at the ratio of

4 the light outputs and multiply it by the candidate

standard level requirement for the standard spectrum.

6 That would create the new candidate standard level for

7 the modified spectrum.

8 So we're at ­­ again, this is a possible way.

9 We're looking for other input, so we're looking for

comments on this method for scaling from standard

11 spectrum to modified spectrum.

12 MR. HOWLEY: This is Joe. I think that's a

13 reasonable approach as long as you consider the true

14 modified spectrum lamps and not the products out there

that would not pass the definition.

16 MR. LEWIS: Doug?

17 MR. BROOKMAN: Yes. Ron Lewis.

18 MR. LEWIS: We were, in the latest

19 legislation, given approval, permission, authority to

not do ANOPRs anymore, and this is a perfect example of

21 where we still choose to have the interaction with

22 stakeholders and put out straw men where we're charged

23 to try to save energy and try to push things. We're

24 given some direction. We've got the spirit of where

they took the general service incandescent lamps and

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1 things that they've done there have given us examples

2 of things.

3 In cases where we didn't have a definition of

4 the modified spectrum, there's no data in existence,

we're in this dialogue. How do we accomplish something

6 that is the best rule where it's considerate of the

7 impacts on manufacturers and it's considerate of saving

8 energy and all the rest.

9 We really are looking for the assist of what

is known. We're talking about all the things we don't

11 know, and because this hasn't been before there's not a

12 history to it. So to the degree that we can get

13 clarity of what is known and where we've got things or

14 methodologies where we can acquire data in a hurry to

help crisp this up and get more precise, we'd really

16 appreciate it.

17 MR. HOWLEY: Ron, this is Joe again. If you

18 wanted to borrow a page out of the EISA, the standards

19 for incandescent A­line lamps, the factor there used

was 25 percent, 25 percent reduction. We know with the

21 products that use the neodymium, which was a previous

22 exemption in the 1992 law, they really do cut the

23 yellow energy considerably, producing a dramatic

24 effect. But it is a 25 percent reduction using that

technology, and that is the technology that was

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1 accepted by Congress for the A­line.

2 So if you're looking for a value to make this

3 simpler, that would be one approach, is to use the

4 value already given for the A­line lamps.

MR. LEWIS: In the spirit of four macadam

6 steps and in statements that have been made a couple

7 times about filtering out the yellow part of the

8 spectrum, is there anything that, with what's being

9 marketed today, where ­­ I think some of the comments

of comparing to eliminating the things that are just

11 token, that the reduction is just token, and the things

12 that are in that realm of the four macadam steps

13 reality. Is there anything that is a first order of

14 qualification that we can look at?

Since we don't have the bare glass lamps

16 versus the final product, is there anything that

17 discriminates easily between those that are token

18 versus those that are real, major ­­

19 MR. HOWLEY: Well, you can look at the lamps

of the major lamp manufacturers who you know well. You

21 can look at their catalogue data if you're trying to

22 get some sense. There are a lot of other products out

23 there, in many cases from importer suppliers, that ­­

24 who knows what they're ­­ how they're approaching it or

if it's just marketing.

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1 But I think if you look at the major

2 manufacturers' data, catalogue data, you'll get some

3 certainty that these products do meet this definition

4 because the NEMA manufacturers came up with that

definition. So we know that all of our products would

6 meet that definition.

7 Perhaps that's the subset you should be

8 looking at versus every single product you can find out

9 on the marketplace.

MR. BROOKMAN: Any final comments on Slide

11 47?

12 (No response.)

13 MR. O'ROURKE: All right. This might be a

14 convenient time to ­­ I don't know if we're going to

take a break this afternoon.

16 MR. BROOKMAN: We are at a point now where ­­

17 MR. O'ROURKE: ­­ going to switch to product

18 price determination.

19 MR. BROOKMAN: Should we take a break now?

Let's take a break.

21 MR. LEWIS: And then everyone's going to come

22 back because Pam's got us waiting for Chapter 2.

23 (Laughter.)

24 MS. HORNER: If you like, I can tell you that

one right now.

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1 MR. LEWIS: No, no. We want everybody to

2 come back.

3 MR. BROOKMAN: Let's take a short break.

4 Let's try to do this in 10 minutes. Let's start at 10

'til three. Then we'll also be assessing at that point

6 how far we're going to get today and how much time

7 we'll need tomorrow.

8 (Brief recess.)

9 MR. BROOKMAN: So, at the break we were

discussing a couple of different things. A couple of

11 different things at the break. One was about the

12 remainder of the day today and tomorrow. Some people

13 have suggested that we should really go quickly. I've

14 heard from several people that they've said about what

they're prepared to say on some of these issues today

16 and maybe they don't have a lot more to say today given

17 their level of preparation.

18 I think also we've ­­ I've heard from DOE and

19 the contractor team that there's a heck of a lot more

slides possibly to go through. There's a question

21 about whether everybody in the room is in a position to

22 endure a hundred more slides. That's another question.

23 But irrespective, we anticipate that some

24 people that didn't make it today might make it

tomorrow, could very well make it tomorrow, so in the

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1 event we did conclude things today, DOE would supply

2 representatives here to walk them through the material,

3 orient them, do whatever is necessary in this very room

4 tomorrow, right? Okay. So that's a certainty.

Now, Mike Scholand, your assessment was that

6 there's a whole lot of slides, a whole lot of content,

7 maybe it's not possible to get through this in the span

8 of even the next two hours if we stay 'til 5 o'clock.

9 MR. SCHOLAND: Just my personal view, Doug.

It's not necessarily the Department's.

11 (Laughter.)

12 MS. GUPTA: What a guy.

13 MR. BROOKMAN: If we did "presentation

14 light," noting that there are a hundred slides or

something left?

16 MS. GUPTA: Yeah, a hundred.

17 MR. BROOKMAN: If we did "presentation

18 light," do you think it's possible to get through this

19 in the span of the next two hours so that some of these

people that will not be with us tomorrow or wish to

21 travel after the end of the day today? Do you think we

22 could do that? Possibly.

23 MS. GUPTA: Maybe two and a half.

24 MR. BROOKMAN: I'm looking at Mike Rivest and

Ron Lewis and Linda Graves, all three here. For the

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1 record this is, yes.

2 (Laughter.)

3 MR. RIVEST: This is Mike Rivest. I think

4 it's important to go over the ANOPR analysis sections,

and then there's the whole series of slides that talks

6 about the next round of analyses. That ­­ I know most

7 people in this room have heard that a hundred times.

8 So we can do those more quickly.

9 And, if needed, we can ­­ we'll be

interacting heavily with manufacturers during the

11 manufacturer impact analysis phase, and that's going to

12 start really quickly because of the delays in issuing

13 the ANOPR. So I'm sure we can have one­on­ones and if

14 there are any questions about subsequent analyses, we

can do that.

16 MR. BROOKMAN: And the actual NOPR slides,

17 that's further up yet, correct?

18 MR. RIVEST: No. They're part of this

19 package.

MR. BROOKMAN: Part of this package here.

21 Okay, fine.

22 MR. DELASKI: Doug?

23 MR. BROOKMAN: Yes.

24 MR. DELASKI: If I can just weigh in.

MR. BROOKMAN: Andrew.

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1 MR. DELASKI: I'm prepared to be here

2 tomorrow. My point of view, I don't want anybody to

3 feel like they need to go "light" because I'm learning

4 a lot today.

MR. BROOKMAN: Great.

6 MR. DELASKI: Other folks may want to get out

7 of here today, but I would appreciate people to keep

8 talking up because we're learning things. We're

9 hearing things from industry and things from the

Department about what their concerns are. I think

11 that's very valuable, so I encourage you not to go

12 "light."

13 MR. BROOKMAN: Okay.

14 MR. DELASKI: I think it's okay to go light

in terms of where ­­ what comes next, but.

16 MR. BROOKMAN: Yeah. Ron Lewis.

17 MR. LEWIS: We won't go backwards to the

18 thing that I mentioned before, but I did want to take a

19 minute to clear up. I'm not sure if everybody in the

room understands that the CSLs and our direction ­­ the

21 methodology we have to go through is, we have to

22 establish what is the max tech that's out there for a

23 product and work our way backwards from that to where

24 is that point that is both technologically feasible and

economically justified. But we start at the highest

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1 level. We're commanded to do that, so we have to go

2 through all these things.

3 So one of the things that I was thinking we

4 could talk about some more but I think we're ­­ to move

along we'll look forward to it in your comments, is in

6 revisiting that Slide 41 on some of the things where

7 there was a problem of perhaps a ­­

8 MR. BROOKMAN: Which is up here now.

9 MR. LEWIS: ­­ a patent or a single

manufacturer. There were several other different

11 design options and things of looking at. Since we've

12 got to start at the highest and stop at that level

13 that's technologically feasible and economically

14 justifiable through the analyses, what are those other

options that are at play. Are there other options.

16 We recognize you're on the record of one

17 option maybe being an impediment, but about the other

18 ones, reconsidering. Because we have to start there at

19 the high point and work down. So that would be very

helpful to us.

21 MR. BROOKMAN: Okay. So then, I guess, then,

22 the direction that I'm receiving is we're just going to

23 press on here. We'll be as efficient as we can. We'll

24 see where we end up.

So then, Mimi.

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1 MS. GUPTA: Okay. Did Pam want to follow up

2 on ­­

3 MS. HORNER: The anticipated follow­up,

4 right?

MR. BROOKMAN: Please, Pam.

6 MS. HORNER: Pam Horner, NEMA. I guess these

7 indeed could be the last two sets of comments I make

8 today because we're really not prepared to comment on

9 the life­cycle analyses and all of the other analyses

because this is ­­ in two weeks this is what we've

11 done.

12 We wanted to make a point in the incandescent

13 reflector lamp area to make you aware of something that

14 has happened in the market. The topic is lamp life.

We understand that DOE does not include lamp life.

16 That is clear. But I think all of us in the room

17 understand that lamp life or the decision, say, to

18 manufacture a product that uses a filament, if one

19 chooses to make longer and longer lamp life products,

then given all other technologies being equal within

21 that product, the lumens per watt go down. It's just a

22 fact of physics.

23 So what we thought we would share with you is

24 something that has happened in the market recently.

There are some I'm just going to call them strategies

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1 of some of the very large purchasers of these products.

2 These strategies are to put into the market, say, one3 year, two­year, three­year, and four­year type life so

4 that, in their eyes, the consumer of these products

will have a choice.

6 We were just talking about this during the

7 break. The lamp life, whether we like it or not, is a

8 top consideration for consumers. So the people who buy

9 our lamps keep that in mind and in essence make a

demand on us, those of us who make these lamps, to

11 fulfill these.

12 We took a look at the curves, the CSL 1, 2,

13 3, and what happens is that at each level, even with

14 those, the four­year strategies that are out there,

which is about 6,000 hours, that sort of thing, will

16 not meet the level.

17 We either say retailers don't matter or their

18 analysis of what their customers want or need doesn't

19 matter. I mean, that's an option.

MR. BROOKMAN: These large retailers are the

21 ones that are requesting that industry come forward

22 with ­­

23 MS. HORNER: Oh, yeah. Yeah.

24 MR. BROOKMAN: ­­ that life expectancy?

MS. HORNER: Yeah, I'm just laying it ­­ I'm

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1 being very plain. I mean, it's simply a reality. I

2 don't know what to do about it yet, but this is fairly

3 recent, okay?

4 MR. BROOKMAN: Okay.

MS. HORNER: The other point is that ­­ I

6 would prefer to take off my NEMA hat right now and wear

7 my Osram Sylvania hat because I don't know that I'm

8 speaking for my colleagues. I think maybe I am, but I

9 don't know that.

When you use lumens per watt as the only

11 metric, which is what we have, and you step back and

12 take a look at what it is we're regulating, it becomes

13 very clear to me that what's left in this incandescent

14 reflector lamp category and what we're talking about

here have now become ­­ the herd is a series of very

16 precise instruments now. They're not light sources

17 that give off the blob of light.

18 Instead, whether we think we can use optics

19 as a measure, whether we think we can legitimately take

a look at anything else, we have lumens per watt.

21 That's what we've got. These are lighting fixtures.

22 They're not fluorescent tubes or A­lamps. I'm just

23 saying, this is a fact and it's been a difficulty. Now

24 that difficulty is coming even more into play as 2008

is upon us. It's more so than in 1992 when we had some

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1 blobs of light in the incandescent reflector lamp

2 world.

3 Now, whether you can use optics or not for

4 regulations, the fact is that the manufacturers have

improved their optics, have improved their shaping,

6 have improved the mounting direction of the filaments.

7 Thereby, through time ­­ you put a slide up there

8 about 11 lumens per watt as a baseline PAR 38. For a

9 lot of us, we maybe can't get to that patented level

but we're pretty darn close through optical

11 improvements.

12 Do you see where I'm headed with this? It

13 can be done through some of those, maybe not to that

14 line level that you've shown. And it begs the question

for the future, you know, when I'm 90 and everyone else

16 in here is 70, I guess, or at least Joe.

17 (Laughter.)

18 MS. HORNER: At some point can we take a look

19 at application efficacy, which is a very brilliant idea

of the Lighting Research Center, one of your

21 consultants, to take a look at how these things are

22 used.

23 To close, I just wanted to give you a point.

24 If you take one of today's 50­watt PAR 30s, you can

take a look at the lumens per watt if you want to. In

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1 our case, it's 13.2. But depending on whether you

2 shape and push those lumens in a skinny direction or a

3 fat direction, you're going to get a whole lot or very

4 little light on the task.

Probably the most dramatic example of this

6 about optics mattering and LPW not mattering when it

7 comes to what do incandescent reflector lamps do, is

8 the case of two non­regulated lamps, the compact

9 fluorescent reflector lamp and the MR16 low voltage

lamp.

11 If you take a 22­watt compact fluorescent

12 reflector lamp today and you stick it somewhere and you

13 aim it at something, from 10 feet away you're going to

14 get one foot candle. That baby is 43 lumens per watt.

The 20­watt MR16 is only 17 lumens per watt, but

16 depending on which beam configuration you choose, you

17 can get 50 foot candles in the middle.

18 What I'm telling you is this is a lighting

19 fixture, not really a lamp. The end.

MR. BROOKMAN: Okay. Thank you. Then let's

21 proceed.

22 MS. GUPTA: All right. So I'm going to go to

23 Slide 48 and talk a little bit about the product price

24 determination. So the purpose of the product price

determination is to establish end user prices for the

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1 lamps and ballasts identified in the engineering

2 analysis. The analysis is based on available price

3 lists such as manufacturer price lists and state

4 procurement price lists.

So for each lamp, DOE developed three prices,

6 a low range, medium range, and high range price, in

7 order to represent the range of prices consumers

8 encounter in the marketplace.

9 The medium price is used as a reference price

in the LCC and is also used in the national impact

11 analysis, and the high and low range prices are used as

12 sensitivities in the LCC analysis.

13 In the product price determination, DOE also

14 developed a weighted average sales tax by region based

on data from Sales Tax Clearinghouse, and the national

16 average was calculated to be 6.9 percent.

17 So I'm going to talk a little bit about the

18 general service fluorescent lamp methodology for

19 establishing prices first. In researching the market,

DOE recognized that higher efficacy lamps or premium

21 lamps generally receive a higher markup or lower

22 discounts off of the blue book prices than lower

23 efficacy lamps.

24 However, in developing prices to be used in

the analyses, in order to reflect commoditization of

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1 the market, DOE mirrored state procurement prices,

2 which reflect bulk purchases. In these state

3 procurement contracts we saw that those purchases

4 received a relatively fixed discount off of the blue

book prices over efficacies and wattages. So DOE

6 applied the same methodology in establishing their

7 high, low, and medium range prices.

8 The low price that DOE developed was

9 developed to be consistent with the state procurement

prices or high volume prices, and we applied a discount

11 to mimic those. The medium range price is consistent

12 with the discount provided by distributors for

13 commercial and institutional consumers, and a 13

14 percent contractor markup was then applied to these

prices.

16 The high price, representing the lowest

17 discount off of the blue book price, is consistent with

18 prices encountered by small quantity purchasers such as

19 Internet prices, and the 13 percent contractor markup

was added to these prices as well.

21 Here we see an example of some end user

22 prices results for the 32­watt T8 four­foot medium bi23 pin lamps. As you can see here, we show a high,

24 medium, and low range price over which they span about

$2. As efficacy increases, you get an increase in end

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1 user price.

2 So DOE requests feedback on the approach for

3 developing end user fluorescent lamp prices.

4 MR. BROOKMAN: Comments? I guess if you

thought this methodology was seriously flawed you would

6 say something; is that correct? Joe.

7 MR. HOWLEY: (Off mic.)

8 MR. BROOKMAN: Joe says it seems reasonable.

9 Thank you. It's nice to get affirmation on these

matters. It allows the Department to move forward.

11 Okay.

12 MR. RIVEST: That's about the highest level

13 of praise we ever get.

14 (Laughter.)

MR. BROOKMAN: That was Mike Rivest, for the

16 record. Okay. Mimi, keep going.

17 MS. GUPTA: Okay. So now I'll talk about how

18 we developed the incandescent reflector lamp prices.

19 For IRL, DOE used a similar methodology as it did with

fluorescent, namely developing discounts off of blue

21 book prices. In its research it did not observe a

22 significant variation of lamp prices, lamp wattage, and

23 therefore mirrored that phenomenon by applying the same

24 end user prices for, for example, the 75­watt PAR 38

lamp and the 90­watt PAR 38 lamp.

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1 However, DOE did notice a difference in lamp

2 prices between lower diameter and higher diameter

3 lamps, PAR 30 and PAR 38 lamps, and therefore it

4 developed separate end user prices for these lamps.

In developing the IRL prices, DOE noticed

6 that the PAR 38 market was a more developed market than

7 the PAR 30 market. Therefore, DOE, first of all,

8 discounts off of PAR 38 blue book prices and then used

9 the PAR 38 analysis as a guide to developing the PAR 30

lamp prices.

11 So, how did we develop the PAR 38 lamp

12 prices. Similar to fluorescent, we mirrored a fixed

13 discount off of the blue book prices, similar to the

14 state procurement contracts. When we developed the low

range price, we made those consistent with both

16 purchases found in state procurement. Medium range

17 prices we developed to be consistent with shipment18 weighted average prices paid by consumers for commonly

19 available IRL. High range prices, which represented

the lowest discount off of the blue book, were made

21 consistent with prices encountered by small quantity

22 purchasers such as Internet prices.

23 So, as I said before, we based the PAR 30

24 price analysis on the results for the PAR 38 lamps. We

did this because we saw that the PAR 30 market seemed

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1 less developed. To do this, DOE developed a modified

2 blue book price for PAR 30 lamps by applying the same

3 incremental differences between the incandescent lamps

4 and higher efficacy lamps from the PAR 38 lamps.

So, just as an illustration, DOE started off

6 with the incandescent technology equivalent of the PAR

7 38 lamp, which is the BR40 lamp, and developed the

8 incrementals from the incandescent to the halogen lamp

9 and used that same incremental to establish the PAR 30

blue book prices. We started off with the incandescent

11 just because we believe that to be the most high volume

12 lamp and commoditized lamp currently.

13 Then, once establishing these modified blue

14 book prices, DOE then applied the same discounts off of

the modified blue book prices as it used with the PAR

16 38 analysis to develop the low, medium, and high range

17 prices.

18 Here is an example of some of our IRL end

19 user price results. For the 75­watt PAR 38 baseline,

similar to GSFL, we show high range, medium range, and

21 low range. As you can see, as lamp efficacy increases,

22 end user price increases as well.

23 So DOE invites feedback on the IRL prices.

24 MR. BROOKMAN: Joe.

MR. HOWLEY: I was just going to say this

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1 also seems like a reasonable approach.

2 (Laughter.)

3 MS. GUPTA: That's great.

4 MR. BROOKMAN: Jeff Harris.

MR. HARRIS: Jeff Harris.

6 MR. BROOKMAN: Get close to the microphone,

7 Jeff.

8 MR. HARRIS: How are you approaching the

9 differences in the enhanced spectrum ­­ modified

spectrum products we talked about earlier given this

11 broad range of apparent performance?

12 MS. GUPTA: Well, we don't directly analyze

13 modified spectrum lamps in the LCC and the NIA because

14 we assume that ­­ if the standard is established

correctly, we assume that the incremental energy

16 savings and the incremental prices in the modified

17 spectrum product class will be the same as the standard

18 spectrum product class and the impact should be

19 similar. Does that make sense? Okay.

MR. BROOKMAN: Steve Nadel.

21 MR. NADEL: I seem confused. I mean,

22 basically you're assuming you have the same, you know,

23 bare lamp and you add some filters to it, but the

24 filters cost the same regardless of whether it's preor post­standard.

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1 MS. GUPTA: Exactly.

2 MR. BROOKMAN: So, Slide 55. Slide 55 is an

3 invitation one more time for you to comment on these

4 five issues: product classes, standards for color

rendering index, selection of efficacious lamp

6 substitutes and candidate standard levels, scaling to

7 product classes not analyzed, and approaches for

8 establishing end user prices. I think we've touched on

9 these at least, if not covered them sufficiently. An

invitation to make final comments.

11 (No response.)

12 MS. GUPTA: Okay.

13 MR. BROOKMAN: Okay.

14 MS. GUPTA: Great, so.

MR. BROOKMAN: On to life­cycle cost

16 analysis. Yes, Gary.

17 MR. FERNSTROM: Gary Fernstrom, PG&E. I'd

18 just like to make an observation here. I find this

19 graph on page 54 to be very interesting. It shows a

range in retail price over on the right­hand side of

21 the graph from roughly $5 to $10. So that's a factor

22 of two. I can buy the product and pay twice as much

23 for exactly the same thing depending upon where I get

24 it.

On the other hand, the cost associated with

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1 going from the least efficacious to the most

2 efficacious is $2 or $3. So I would be far better off

3 to be a wise shopper and get the best light bulb.

4 MS. GUPTA: You mean the best light bulb in

high volume; is that what you're saying?

6 MR. FERNSTROM: Well, even the way I shop, I

7 find this price range difference in retail. So I can

8 go to a big box hardware store and find a lamp for half

9 the price that I would at a small distributor. So I

think if we were all, you know, wise shoppers, we could

11 buy the best light bulbs and have them be less

12 expensive than if we just bought the worst light bulbs

13 at the wrong place.

14 MR. BROOKMAN: Mike Rivest.

MR. RIVEST: That's certainly true. A couple

16 of clarifying points, though. You know, the low end of

17 the range represents, I believe, the largest state

18 pricing.

19 MR. FERNSTROM: High volume.

MR. RIVEST: The high volume. So there's

21 that aspect. And then, we are not ­­ the price of the

22 19 lumen­per­watt lamp, if you try to buy it today you

23 will pay a lot more than that for it because the

24 discount on a base lamp is ­­ I'm going to make this up

­­ is 60 percent off blue book and on the very high

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1 efficiency product it might be 40 percent off blue

2 book. Here it's assuming constant 60. So we're

3 commoditizing a lot here.

4 MR. FERNSTROM: Yeah, that's a very good

observation. If I could even find the best product,

6 which a lot of times is just not available.

7 MR. BROOKMAN: Keith has a comment.

8 MR. COOK: Can you hear me? But that

9 analysis is exactly what's got us into problems today,

and that is the fact that everybody is looking at

11 initial cost and not life­cycle cost. It's led us

12 astray so many times that you look at that minimum

13 price. No matter how efficient it is, it still may not

14 be the best product over the long term because you have

to take into account how long the product lasts and

16 what the overall efficiency is of that product.

17 So, you know, we've got to get away from that

18 initial cost mentality.

19 MR. LEWIS: So, are you suggesting we should

consider life­cycle cost?

21 (Laughter.)

22 MR. BROOKMAN: The perfect segue, the perfect

23 segue. Diana Burk.

24

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1

2 Life­cycle Cost Analysis and Payback Period Analysis

3 Diana Burk

4 (PowerPoint presentation.)

MS. BURK: Thanks for queuing me up. My name

6 is Diana Burk, and I'll be talking about the life­cycle

7 cost analysis. I'll also be talking about the energy

8 use characterization.

9 The energy use characterization is an

important analysis which feeds directly into the life11 cycle cost analysis. This analysis gives consumer

12 energy use by efficiency level. The life­cycle cost

13 analysis uses results from the energy use

14 characterization as well as the engineering and product

price determination, which gives you results of

16 efficiency with price.

17 So the purpose of the energy use

18 characterization is to develop energy consumption

19 estimates for those lamps or lamp and ballast systems

that we developed in the engineering analysis. The

21 purpose of the life­cycle cost analysis is to estimate

22 the amount of money a consumer will save by purchasing

23 a higher efficiency lamp. This estimate takes into

24 account both the first cost of purchasing the lamp as

well as the operating costs over the lifetime of that

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1 lamp.

2 So there are two basic inputs to the energy

3 use characterization: operating hours and power of the

4 lamp or lamp and ballast system. For operating hours,

DOE developed a distribution of operating hours by

6 several variables: lamp type, sector, building type,

7 and region. Of course, by lamp type, DOE assumes that

8 incandescent reflector lamps will operate for different

9 annual operating hours than general service fluorescent

lamps.

11 DOE developed a distribution for these lamp

12 types in different sectors. For incandescent reflector

13 lamps, DOE developed a distribution for the

14 residential, commercial, and industrial sector, and for

fluorescent lamps in the commercial and industrial

16 sector.

17 The distribution of operating hours also

18 varies by building type. A certain lamp may have lower

19 operating hours in a vacant building versus a lamp

operating in an office. Operating hours will also vary

21 by the region of the country the lamp is located in.

22 DOE analyzes 13 regions, nine census divisions, or four

23 large states.

24 Power used in the energy use characterization

was developed in the engineering analysis. For

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1 incandescent reflector lamps, it's simply the lamp

2 wattage, and for fluorescent lamps it's based on the

3 system power, which depends both on the lamp and the

4 ballast.

DOE developed operating hours for all three

6 sectors, as I stated earlier. To develop operating

7 hours in all three sectors, DOE used the 2002 U.S.

8 Lighting Market Characterization. This report was used

9 to develop an average operating hours by building type

and lamp type. DOE chose to develop the distribution

11 of operating hours by building type to represent the

12 average energy use of a lamp for a particular consumer

13 who would purchase lamps for the entire building.

14 DOE also used the Residential Energy

Consumption Survey. This report was used to develop

16 probability a certain building type resides in a

17 certain region of the country.

18 Using these two sources, DOE found that the

19 average operating hours of an incandescent reflector

lamp was 884 hours per year. Because the range of

21 operating hours by building type in the residential

22 sector was quite small, DOE also developed a

23 sensitivity for high and low operating hours by room

24 type. The high operating hours used was 1,210 hours

per year, which corresponds to a lamp operating in a

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1 kitchen, and 183 hours per year, which corresponds to a

2 lamp operating in a closet.

3 (Laughter.)

4 MS. BURK: In the commercial sector, DOE also

used the 2002 U.S. Lighting Market Characterization.

6 Again, this report was used to develop an average

7 operating hours by building type and lamp type. In the

8 commercial sector, building types range from offices,

9 refrigerated warehouses, lodging, and food sales. DOE

also used the 2003 Commercial Building Energy

11 Consumption Survey. This gave the probability a

12 certain building type resides in one of nine census

13 divisions or four large states.

14 The operating hours for an average

incandescent reflector lamp was found to be 3,450 hours

16 per year, and the operating hours of an average

17 fluorescent lamp was found to be 3,435 hours per year.

18 This is a sample distribution of operating

19 hours in the commercial sector for fluorescent lamps.

As you can see, the highest probability of a

21 fluorescent lamp being located is an office, which is

22 number two. Approximately 18 percent of fluorescent

23 lamps are located in offices. The average operating

24 hours for a fluorescent lamp in an office is

approximately 3,700 hours per year.

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1 Finally, DOE developed operating hours for

2 the industrial sector. Again, DOE used the 2002 U.S.

3 Lighting Market Characterization. This time building

4 types ranged from printing and publishing to fabricated

metal products.

6 DOE also used the 2002 Manufacturer Energy

7 Consumption Survey, which gave the probability a

8 certain building type resides in the country. Because

9 the survey did not include information on the location

of those manufacturing facilities, DOE used information

11 from the 2007 census to determine the probability a

12 certain building type would reside in one of the nine

13 census divisions or four large states.

14 The average operating hours for an

incandescent reflector lamp in this analysis was found

16 to be 4,664 hours per year, and the average operating

17 hours for a fluorescent lamp was found to be 4,795

18 hours per year.

19 Finally, I'm going to open up the floor for

comment. DOE requests feedback on these average

21 operating hours and whether they're reasonable

22 estimations.

23 MR. BROOKMAN: So, both confirming the result

24 and also any comments about the methodology.

MS. HORNER: Dare we say it seems reasonable?

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1 (Laughter.)

2 MR. BROOKMAN: Okay. I'm glad we captured

3 that on the record. Okay. Any other comments? Jeff

4 Harris.

MR. HARRIS: Yeah, I have a question. Jeff

6 Harris. As I recall, the Lighting Market Survey was

7 not a regionally differentiated one that was done in

8 2002. Do I remember wrong?

9 MS. BURK: No, that is correct. That is why

DOE used the Residential Energy Consumption Survey,

11 RECS, CBECS, Commercial Building Energy Consumption

12 Survey, and MECS, which gave the probability of

13 building types. The U.S. Lighting Market

14 Characterization gave the average operating hours for a

certain building type, but it did not say where those

16 building types were located, whereas RECS, MECS, and

17 CBECS gave the probability a certain building type

18 would be located in a certain region.

19 MR. HARRIS: Okay. I guess I understand

that. But in the residential sector, it seems to me

21 that, first of all, we're talking basically about

22 reflector lamps which are mostly likely to be in

23 ceiling fans and most likely to be in newer houses.

24 MS. BURK: Right.

MR. HARRIS: So there would tend to be a

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1 concentration of those in the fast­growing regions,

2 which are the Southeast and Southwest.

3 MS. BURK: Right.

4 MR. HARRIS: And I would expect to see more

differentiation in lighting hours.

6 MS. BURK: Between in the different regions?

7 MR. HARRIS: Between the south and the north,

8 for example, than by building type.

9 MS. BURK: We did develop different

distributions by region. However, the U.S. Lighting

11 Market Characterization would only give you the

12 operating hours for like a single family attached

13 house. If there are more single family attached houses

14 in, say, the Northeast than the south, then you would

see that differentiation. But otherwise, you wouldn't.

16 MR. HARRIS: So you assumed different

17 operating hours by latitude?

18 MS. BURK: By building type. A mobile home

19 may have different operating hours than a person living

in a single family detached house.

21 MR. RIVEST: But a mobile home in ­­

22 MR. BROOKMAN: Mike Rivest.

23 MR. RIVEST: But a mobile home up north would

24 have the same operating hours as a mobile home down

south.

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1 MS. BURK: Right. A mobile home up north

2 would have the same operating ­­

3 MR. RIVEST: But the number of mobile homes

4 would be greater in the south.

MR. HARRIS: I don't remember the exact

6 numbers, but it's my, again, vague recollection that

7 the overall residential lighting energy as a fraction

8 of total electricity from that study was lower than

9 we've seen in subsequent studies, especially regional

ones.

11 I'm going to turn to Tom Eckman in particular

12 because I recall that some more detailed work has been

13 done in the Northwest. If I recall, it showed more

14 lighting, but I don't know if it was by hours or by

connected load.

16 MR. BROOKMAN: Get to the mic, Tom.

17 MR. ECKMAN: Can you hear this? Because this

18 is pretty much what it's got to be.

19 Well, as I recall, one of the principal

reference studies in the Lighting Market

21 Characterization where we actually did have in situ

22 lighting loggers was done in Tacoma, which sits at

23 about the 46th Parallel. So it may be different than

24 the folks in southern California because it does get

dark there more often in the winter.

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1 But I think that there are only two metered

2 studies or two logged studies that were referred to in

3 that. The other one that I'm familiar with that was

4 done more recently was done and finished in '96. The

other one was done in California. It was pretty much

6 representative of all California.

7 When we compared the two averages, they were

8 a tenth of an hour per day different. So latitude

9 doesn't seem to have a major impact given sunny

California and rainy Tacoma.

11 MR. BROOKMAN: Would you confirm the building

12 type hypothesis?

13 MR. ECKMAN: The building type hypothesis,

14 you know, both of those were done as well. The metered

data that was done in California was across all three

16 building types that you were looking at: single17 family, multi­family, and manufactured homes. The

18 Tacoma was only done in single­family, so I can't speak

19 to the variance there.

MR. BROOKMAN: Thank you.

21 MR. ECKMAN: But for new construction, the

22 power densities are much higher and the buildings are

23 much larger, and there's a higher prevalence of the can

24 lines where these things would go. We are doing now,

but it won't be ready for this study, we're going in

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1 the field now with lighting loggers in those homes.

2 But because we're looking at 30 or 40 cans per home.

3 MR. BROOKMAN: Gary.

4 MR. RIVEST: Can I make an observation? This

product is unlike other products. If we're talking

6 about a clothes washer, we assume it lasts 14 years.

7 If it gets used twice as much, we assume it lasts 14

8 years anyway. Lighting, if this is good for 2,000

9 hours, it's good for 2,000 hours.

Now, the difference is that you may recover

11 your cash flow in the two years instead of one, but

12 that is a small difference. So operating hours is not

13 the driver it is in other analyses.

14 MR. BROOKMAN: Gary.

MR. FERNSTROM: Okay. Gary Fernstrom, PG&E.

16 Just one more observation about the can lights. New

17 homes have more can lights and they tend to be in rooms

18 that are occupied longer hours. So I think that

19 factors in also. You find the can lights in the

kitchens and living rooms, not in the closets.

21 MR. BROOKMAN: Okay.

22 MS. BURK: Shall I move on?

23 MR. BROOKMAN: Yeah.

24 MS. BURK: So, an additional input to the

energy use characterization is the power of the lamp or

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1 lamp and ballast system selected in the engineering

2 analysis. As I stated earlier, for incandescent

3 reflector lamps the power is simply the wattage of the

4 lamp. But for fluorescent lamps, the system power

depends both on the lamp and the ballast it is operated

6 by.

7 DOE calculated the system power rating using

8 published catalogue data to estimate the system power

9 for a range of ballast factors with similar attributes.

For example, similar ballast efficacy factors, THD,

11 total harmonic distortion.

12 DOE developed a linear fit. This is an

13 example of a linear fit for a three­lamp, 32­watt,

14 four­foot T8 system with a normal ballast efficacy

factor and normal total harmonic distortion.

16 DOE invites comments on all the system power

17 ratings of the lamp and ballast systems analyzed in the

18 energy use characterization.

19 MR. BROOKMAN: Steve Nadel.

MR. NADEL: No, this seems reasonable. I

21 mean, it's a straight line function. The ballast

22 factor.

23 (Laughter.)

24 MR. NADEL: Don't let this go to your head.

(Laughter.)

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1 MR. BROOKMAN: Other comments?

2 (No response.)

3 MR. BROOKMAN: Okay.

4 MS. BURK: Okay. So now let's move on to the

life­cycle cost and the payback period analysis. As I

6 stated earlier, the purpose of the life­cycle cost and

7 payback period analysis is to estimate the life­cycle

8 cost savings and the payback period for higher

9 efficiency lamps compared to the baseline lamp.

Here is a brief overview of the basic life11 cycle cost methodology. The life­cycle cost, or the

12 LCC, is the cost of owning and operating a piece of

13 equipment over its lifetime. The LCC is comprised of

14 first costs, shown here, the consumer price plus the

installation cost of installing the lamp or lamp and

16 ballast, and the operating expenses of that system over

17 the analysis period. This is discounted to present

18 value in the analysis.

19 The analysis of the LCC is done from the

perspective of the consumer, as opposed to the

21 manufacturing impact analysis, which is done from the

22 perspective of the manufacturer.

23 For transparency, this analysis tool is

24 implemented in Excel, which you can download from the

DOE website. It includes the ability to explore

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1 certain sensitivities to key input variables in the

2 analysis.

3 The LCC results are expressed as the

4 difference between the life­cycle cost of the baseline

minus the lamp that meets the candidate standard level.

6 In addition to calculating the net life­cycle cost

7 impact of each candidate standard level, the life­cycle

8 cost analysis tool also shows the simple payback period

9 for each candidate standard level.

Later in this presentation I'll elaborate on

11 the life­cycle cost methodology for the lamps

12 rulemaking.

13 The approach taken in this analysis, DOE

14 makes, you know, several important decisions for this

analysis. This analysis only considers consumer

16 choices that save energy. For example, reduced wattage

17 lamps or lamp and ballast combinations that have

18 reduced system power. DOE does not consider those

19 options that do not save energy, however recognizes

that consumers may choose not to save energy when a

21 candidate standard level is applied. They can just

22 increase the light output of the product. DOE

23 considers these options in the national impact

24 analysis.

DOE recognizes that the event that triggers

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1 the purchase of a lamp will affect the impacts of a

2 standard on the consumer. We will talk about these

3 events in more detail in the next slide.

4 DOE also recognizes that the lifetimes of

lamps may be different at different standard levels.

6 Therefore, DOE uses something called a residual value.

7 Again, we'll talk about this later.

8 Finally, it is important to note that in the

9 analysis DOE uses a distribution of several inputs.

For example, DOE uses a distribution of operating

11 hours, sales tax, and electricity prices. These inputs

12 are correlated in the analysis. For example, these

13 distributions are correlated by region.

14 Various events trigger the purchase of a

lamp. We'll go over these events generally here and

16 then go into more specifics in the slides to come. For

17 incandescent reflector lamps, there are basically two

18 events that might trigger the purchase of a lamp. This

19 is the event where a lamp fails and must be replaced, a

lamp failure event, or the new construction and

21 renovation event, where a building is being constructed

22 or renovated.

23 For fluorescent lamps, there are multiple

24 events. DOE analyzes five events for fluorescent

lamps. Of course, the first is the lamp failure event.

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1 A lamp fails and must be replaced.

2 The second is the standards induced retrofit

3 event. In this event, an increase in the efficacy

4 standard prompts end users to retrofit their lamps and

ballasts when in the base case they would have

6 otherwise only purchased a lamp. This event is

7 particularly salient at certain candidate standard

8 levels, Candidate Standard Levels 4 and 5, when a user

9 with a T12 system would no longer be able to purchase a

T12 lamp for that system and would be forced to

11 retrofit with a T8 system in the standards case.

12 The third event DOE analyzes is the event

13 when a ballast fails. Under this event, a consumer

14 must replace both their lamp and ballast in the base

and the standards case.

16 The fourth event is the event when a consumer

17 is planning to retrofit their building. In the case of

18 the standards, these consumers would be forced to

19 retrofit with a higher efficacy lamp when they wouldn't

have otherwise.

21 Finally, the fifth event is for those lamps

22 being purchased for a newly constructed building. In

23 this event, the lighting design can be new or

24 completely reconfigured.

As we talked about before, we analyzed the

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1 economics on several baseline lamps, T12 and T8

2 baseline lamps, for certain product classes. DOE

3 recognizes that certain triggering events may be more

4 salient for T12 baseline lamps than they are for T8

baseline lamps. I'll go over the base case and the

6 standards case action for T12 baseline lamps here and

7 talk about the salient events for T8 baseline lamps in

8 the slide to come.

9 For the lamp failure event, the base case

action is simple: simply install a new T12 lamp.

11 However, in the standards case, the user can either

12 install a lower wattage, higher efficacy lamp and

13 maintain light output or they can install a new T12 or

14 T8 system. This would be an electronic system.

If the standard is set at Candidate Standard

16 Level 4 or 5, candidate standard levels which T12 lamps

17 would not be able to meet, many lamp purchases may be

18 made under the standards­induced retrofit events. In

19 this event, buildings who own T12 systems may replace

their systems before the lamps in their buildings

21 actually fail. Therefore, in the base case, the

22 buildings would replace a lamp halfway through the

23 analysis period, but in the standards case they would

24 purchase a T12 or T8 electronic ballast at the

beginning of the analysis period.

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1 A lamp may also be purchased under the

2 ballast failure event. Under this event, because the

3 magnetic T12 ballasts will no longer be available, a

4 base case action would be to install a T12 electronic

ballast, if one were to want to buy a T12 lamp. And in

6 the standards case, one would have to install either a

7 T12 or a T8 electronic lamp at a higher efficacy.

8 The fourth event is the ballast retrofit

9 event. DOE assumes that consumers of T12 lamps would

not retrofit with a T12 system. They would only

11 retrofit with a T8 system. Therefore, in the base case

12 consumers would install T8 electronic ballast lamps in

13 their existing buildings. However, in the standards

14 case, they would install a higher efficacy T12 or T8

lamp.

16 For the new construction and renovation

17 events, DOE assumes this is only applicable to the T12

18 high output systems. DOE assumes that new buildings

19 are not being constructed using four­foot T12 or eightfoot T12 single­pin slimline systems. In this case, a

21 user in the base case would install a new T12 high

22 output system, but in a standards case would install a

23 new T12 or T8 system where the light output is

24 maintained.

MR. BROOKMAN: Yes, Tom.

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1 MR. ECKMAN: I'm not quite clear how ­­ this

2 is Tom Eckman, Northwest Power and Conservation

3 Council. In the new construction and renovation cases,

4 I'm not quite clear; for those areas of the country

that have building codes that require maximum ­­ set

6 maximum lighting power densities, in many areas being

7 able to satisfy that, you just can't get there with a

8 T12 today, at least in our neck of the woods down in

9 California.

So the presumption that they could use that

11 as an option just isn't realistic. Now, there may be

12 areas of the country where that's possible, but a fair

13 chunk of the country is covered by areas where that

14 option doesn't exist.

MR. BROOKMAN: Thank you. Yes, please, Paul.

16 MR. WALITSKY: Paul. If you've got to go to

17 an Energy Star or U.S. Green Building Council lead, you

18 can't use T12s, either. It won't work. You won't get

19 to the desired level on the Energy Star scale to get

your points.

21 MS. BURK: Is that it? For T8 lamps, DOE

22 assumes only three events are applicable: the lamp

23 failure, ballast failure, and new construction and

24 renovation events. For all three events DOE assumes

the user will install a T8 lamp in the base and

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1 standards case.

2 Another important part of the life­cycle cost

3 analysis is the use of residual values. To compare the

4 life­cycle cost of two products, one must evaluate them

over the same period of time. This period of time must

6 be based on the lifetime of the product being

7 regulated.

8 For lamps, DOE recognizes that lifetimes may

9 vary at different candidate standard levels. To take

into account this variance, DOE uses something called a

11 residual value. This value prorates the value of the

12 remaining life of the lamp or ballast in the analysis.

13 So if one is estimating the residual value of

14 a $6, six­year lamp with a five­year analysis period,

at the end of the five­year analysis period a six­year

16 life lamp has one year of life left. So the residual

17 value would be one­sixth of the price of that lamp.

18 One­sixth of $6 would be $1. This $1 would be

19 discounted back to present value in the analysis from

the end of the analysis period.

21 The total life­cycle cost for a lamp that

22 lives longer than the analysis period is equal to the

23 installed cost of that lamp plus its operating costs

24 minus the residual value of that lamp.

DOE seeks comment on the use of residual

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1 value and on other possible approaches to calculating

2 life­cycle cost for products with varying lifetimes.

3 MR. BROOKMAN: Yes, Gary.

4 MR. FERNSTROM: Gary Fernstrom, PG&E. This

is a little off the subject, but we talked about

6 ballasts earlier in fluorescent lighting systems and

7 the economics associated with them. Are ballasts

8 treated similarly in terms of their residual value when

9 T12 ballasts need to be replaced?

MS. BURK: Yes, they are. If the analysis

11 period lasts, for example, five years and a fluorescent

12 lamp ballast, say, will last 15 years, then the

13 consumer actually pays for one­third of that ballast

14 for the life­cycle cost calculation.

MR. FERNSTROM: Thank you.

16 MR. BROOKMAN: Steve.

17 MR. NADEL: It seems like a reasonable

18 approach. It's much easier than trying to come up with

19 all sorts of permutations of different lamps and

ballast lives.

21 One question. What ballast life did you

22 assume? Is it in years or in hours?

23 MS. BURK: It is in hours, and we took it

24 from the 2000 ballast rule. I'll talk about it later,

but it's approximately 49,000 hours.

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1 MR. BROOKMAN: Paul.

2 MR. WALITSKY: The one point I ­­

3 MR. BROOKMAN: Oh, you weren't done?

4 MR. WALITSKY: ­­ would mention is on lamp

maintenance values. As the lamp gets older, you're

6 getting out less light output. Would that come into

7 the residual value?

8 MS. BURK: In the life­cycle cost analysis

9 DOE does not include any maintenance costs for lamps.

However, it does take into account group and spot

11 replacements. So a group replacement would be

12 estimated 75 percent of the rated life and a spot would

13 be made at the end of the rated life.

14 MR. FERNSTROM: Gary Fernstrom, PG&E. Well,

if we want to carry that thinking one step further,

16 since there is a cost associated with disposal, is that

17 treated in the residual value?

18 MS. BURK: No. We do not take that into

19 account in the residual value. So I would assume that

the disposal of the lamp would be the same in the base

21 and the standards case, and so the life­cycle cost

22 savings, well, may be affected a little bit if the

23 lifetime is a lot shorter.

24 MR. BROOKMAN: Steve Nadel.

MR. NADEL: Yeah. You may want to look again

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1 at the ballast life. As I recall, even in the last

2 ballast rulemaking there was a bunch of discussion and

3 that was perceived then to be a very conservative

4 value.

MS. BURK: Okay.

6 MR. BROOKMAN: Paul again.

7 MR. WALITSKY: Paul again. One comment on

8 recycling. Costs range anywhere now from five cents a

9 foot up to 10 cents a foot. It's come down somewhat

from the standard of 10 cents, but it's still ­­ a

11 four­foot lamp, your residual value is going to be

12 eaten up in the recycled foot.

13 MR. BROOKMAN: Okay.

14 MS. BURK: Thank you.

MR. BROOKMAN: Other comments on recycle ­­

16 residual value?

17 (No response.)

18 MS. BURK: Okay. This diagram illustrates

19 the simple cash flow for one of the events, the T12

lamp failure event. The red arrow is the lamp

21 purchased. The green arrows are the operating

22 expenses, and the blue arrow is the residual value.

23 So in the base case, if you had a T12 lamp on

24 a magnetic ballast and it had a five­year service life,

the analysis period would be based on this five­year

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1 service life. So, 2012. The consumer would purchase

2 the lamp. They would then have to pay operating

3 expenses at the end of each year throughout the

4 analysis period, which would end in 2017.

In the standards case, one would purchase a

6 reduced wattage T12 lamp on that same ballast. If that

7 lamp had a six­year service life, one would encounter a

8 residual value at the end of the analysis period.

9 The purchase price, of course, in 2012 may be

higher. The operating expenses throughout the analysis

11 period would be lower, and then you would see the

12 residual value, one­sixth of the lamp price at the end

13 of the analysis period, discounted back to present

14 value.

This is a draft concept of how we've

16 structured the life­cycle cost analysis. It may look

17 pretty confusing now.

18 (Laughter.)

19 MS. BURK: I will go over these inputs

generally here and talk about them in more detail in

21 the slides to come.

22 We've talked a bit about the installed cost,

23 where the main component is the lamp price. We'll talk

24 about the installed cost in the next slide, where we

also include installation costs in the life­cycle and

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1 payback period analysis.

2 Operating costs are derived from energy

3 consumption and energy prices. I've talked about

4 energy consumption in the energy use characterization,

but we'll talk about energy prices in the slides to

6 come.

7 The operating cost over the analysis period

8 is calculated by discounting the operating cost and

9 taking into account the electricity price trends.

Again, I'll talk about discount rates and electricity

11 price trends in the slides to come.

12 The simple payback is the difference between

13 the total installed cost of the baseline and standards

14 case product divided by the annual electricity cost

between the baseline and the lamp that meets that same

16 candidate standard level. The life­cycle cost is the

17 addition of the total installed cost, the operating

18 expenses, And the replacement cost if the lamp dies

19 before the end of the analysis period. The residual

value is also taken into account.

21 For total installed cost, the total installed

22 cost of the lamp or lamp and ballast system is the

23 retail price plus the installation cost. The equipment

24 retail price is derived from the product price

determination. It's simply the sales tax times the end

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1 user product price.

2 The installation costs represent the labor

3 necessary to install the lamp or lamp and ballast. For

4 labor times, DOE ­­ for fluorescent lamps, DOE used

information from the 2000 ballast rule. These labor

6 times depended on the lamp being installed. DOE also

7 used the weighted average group and spot labor time

8 rate.

9 For incandescent reflector lamps, DOE used

labor time estimates from the 2007 RS Means Electrical

11 Cost Data. In the residential sector, DOE assumes no

12 installation cost for incandescent reflector lamps.

13 MR. FERNSTROM: Gary Fernstrom, PG&E. This

14 is a small point, but shouldn't the equipment retail

price be the end user price plus sales tax?

16 MR. RIVEST: Yes.

17 MS. BURK: Yes.

18 MR. RIVEST: Sales tax rate.

19 MS. BURK: Yeah. It would be sales tax ­­ it

would be one plus the ­­ so if the sales tax was 6.9

21 percent, then the equipment retail price would be the

22 end user product price times one plus the 6.9 percent.

23 MR. FERNSTROM: So, to be picky, that's

24 mathematically incorrect.

(Laughter.)

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1 MS. BURK: Fatally flawed.

2 (Laughter.)

3 MS. BURK: We did the calculation correct in

4 the spreadsheet.

(Laughter.)

6 MR. FERNSTROM: I had confidence you did the

7 calculation correctly.

8 MS. BURK: For labor rates, DOE assumed a

9 lamp was being replaced by a general maintenance

worker. DOE obtained the labor rate for this

11 maintenance worker from the U.S. Bureau of Labor

12 Statistics and found it to be $15.49 an hour. The

13 labor rate for the lamp and ballast replacement was

14 assumed to be an average of an electrician and

electrician's helper labor rate, and this was found to

16 be $53.88 an hour.

17 MR. BROOKMAN: I was wondering why that was

18 so low. Yes, Steve Nadel.

19 MR. NADEL: A comment on the electrician

rate. Yes, that makes sense for a smaller customer who

21 needs to hire an electrician, but a lot of large

22 customers will have electricians on staff and they're

23 not paying that. So you may want to ­­ again, it may

24 be Bureau of Labor Statistics or something, you know,

an on­staff electrician. I don't know what the, you

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1 know, large versus small is, but, you know, some factor

2 to account for that.

3 MS. BURK: Okay. Any other comments?

4 MR. BROOKMAN: Keith.

MR. COOK: Sorry. On the replacement rate,

6 there's other factors in that also that aren't

7 accounted for. I don't know if it's worth going into,

8 but you know, you have to have forklifts and things

9 like that in order to get up into high bays and those

kind of places ­­

11 MS. BURK: Right.

12 MR. COOK: ­­ for replacement. Those are not

13 cheap.

14 MS. BURK: Right. Well, DOE took into

account labor times from the data from the 2000 ballast

16 rule, which would include any forklifts needed to go up

17 to high bays. These do depend on lamp height, but if

18 you feel that they don't represent the actual labor

19 times, we'd welcome any comments.

MR. BROOKMAN: Steve Nadel.

21 MR. NADEL: Yes. I mean, in general, the

22 lamp has failed. You are going to have to get up there

23 anyway. So, do you need more forklift time. You know,

24 do you need to get a new forklift or something. I

think for the most part, if anything, the new lamps are

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1 longer­lived and you have 24,000 replacing 20,000.

2 MS. BURK: Right.

3 MR. NADEL: I can't think of instances where

4 it's a shorter lamp life we're now using and therefore

you're going to need to change it more often.

6 MS. BURK: Right. You bring up a good point.

7 The only instances where installation costs really

8 matter is when the lifetime is different and one might

9 have to install a lamp more often in the base or

standards case than the other lamp.

11 MR. BROOKMAN: Okay.

12 MS. BURK: Okay. DOE understands that labor

13 times do not take into account new regulations from the

14 2005 National Electric Code. This code requires a

means for disconnecting luminaires installed indoors

16 and thus may affect the labor time to install

17 fluorescent lamp ballasts. This rule came into effect

18 in January of this year, so we welcome comments on how

19 this new requirement may affect labor times and labor

rates we're using in the analysis currently.

21 MR. BROOKMAN: Has industry estimated ­­ Joe.

22 MR. HOWLEY: Yes, Joe Howley. It definitely

23 would add a factor. You are correct in that the NEC

24 did add this new requirement that requires a

disconnect. In most cases, this disconnect is being

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1 addressed through a separate in­line connector that now

2 they have to wire into the system.

3 So it would take some additional time. I

4 don't have an estimate of how long that would be, you

know, whether that would be 15 minutes, 30 minutes. I

6 can't imagine it would be more than something in that

7 range. But you might, you know, at a minimum, my gut

8 feel is probably at least 15 minutes added, maybe a

9 quarter of an hour at the most to add that.

MR. BROOKMAN: Steve Nadel.

11 MR. NADEL: I'm curious because I'm not

12 familiar with this. Does this apply just to new

13 fixtures or if you have an existing fixture and a

14 ballast is being replaced do you have to ­­ does this

trigger that? Because we have relatively few new

16 fixtures. We have a lot of ballast replacements.

17 MR. HOWLEY: Right. I believe the code is if

18 you're doing a major retrofit you have to ­­ and you

19 have to pull a permit. That has to be changed. I

don't know how it affects individual fixtures. I could

21 go back and check that with their standards people.

22 MR. BROOKMAN: Keith, do you know how this

23 works?

24 MR. COOK: Yeah. It does affect fixtures for

field replacements, and so what the fixture

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1 manufacturers are doing are actually shipping a

2 connector along with the fixture right now and then

3 it's field­installed.

4 MR. NADEL: Right. So my question was, does

it also affect ballast replacement. If you do not

6 replace the fixture, just replace the ballast ­­

7 MR. COOK: No, it does not affect the ballast

8 right now.

9 MR. NADEL: Okay. Thank you.

MR. BROOKMAN: Yes, Paul.

11 MR. WALITSKY: Yeah, just from the real

12 world, we just relamped a school in Atlantic City. We

13 took about 20 minutes per fixture. And these were

14 ceilings about this height, and the local electrician

did it. He changed about ­­ about three fixtures an

16 hour is what he worked on. Just changing the ballast

17 and changing the lamp. These were four­lamp and two18 lamp.

19 MR. BROOKMAN: Okay.

MR. WALITSKY: So that's current data right

21 from the field.

22 MS. BURK: Thank you.

23 MR. BROOKMAN: Great. Thank you.

24 MR. FERNSTROM: Gary Fernstrom, PG&E. Just a

clarification on that. I just heard that the

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1 disconnect is shipped with the fixture. So, what's the

2 difference if I wire up a new fixture without a

3 disconnect or I wire up a new fixture with a

4 disconnect? Either way I'm connecting from the

building distribution system to the fixture.

6 (Pause.)

7 MR. BROOKMAN: We're not getting any response

8 to that. Ron Lewis.

9 MR. LEWIS: I think we're introducing an

element here that's not really in play, though, with

11 the fixtures. We're talking about ballasts and lamps.

12 I think the question was existing stock versus new.

13 So I don't want to have us chasing down roads to

14 collect a lot of data that we can't use.

It's a good point and I don't want to ever

16 cut off the conversation or input. I think in this

17 case the new fixtures and the disconnect in the

18 electrical code is for the luminaires, not for

19 replacing a ballast that's within the luminaire,

especially if it's only when it's a ­­ the same as most

21 of the other building codes. There are major retrofits

22 or renovations and new construction that are like half

23 or better, you know, a major thing where they need to

24 get a permit. We're talking about the majority of

replacements of lamps or ballasts are not going to fall

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1 in that category.

2 So we can collect a lot of data and try to

3 introduce some artificial precision that's maybe not

4 going to lead us towards the efficacy standards that we

need to get to.

6 MR. HOWLEY: We can research this and get you

7 more specific data on exactly when it's required. It's

8 not real clear exactly in what cases it's required. We

9 have to research into this.

MR. BROOKMAN: Thanks, Joe.

11 MR. NADEL: Thank you. I understand the

12 relevance.

13 MR. BROOKMAN: Okay.

14 MS. BURK: Okay. Now let's talk about

electricity prices. The electricity prices DOE used in

16 this analysis were based on EIA Form 861. This form

17 provides the revenues of electricity sales for each

18 utility, what sector these revenues are based in, the

19 location of the utility, and the amount of customers

for that utility within each sector.

21 Based on this data, DOE developed electricity

22 prices for three sectors: the commercial, residential,

23 and the industrial sector, and for nine census

24 divisions in four large states.

In the life­cycle cost analysis, DOE used the

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1 weighted average prices for the basic calculation and

2 the distribution in the Monte Carlo analysis.

3 MR. FERNSTROM: Gary from PG&E again. I wish

4 I see PG&E ­­ not PG&E but California at 9.9 cents.

Our average rates now are right around 14 cents.

6 MS. BURK: Okay.

7 MR. FERNSTROM: Across the board, all

8 sectors.

9 MS. BURK: This was based on 2007 data, but

if we get new data we can update these prices.

11 MR. FERNSTROM: Well, I can hardly believe

12 it's changed that much since then.

13 MR. COOK: I even thought the DOE­collected

14 data on the website showed 2007 California at 12.4

cents a kilowatt­hour.

16 PARTICIPANT: Could this be '06 data?

17 MS. BURK: I think it's EIA Form 861. Sorry.

18 I think it's 2005 data, actually. Yeah. It's the

19 most recent EIA form. If there's a new form that comes

out, we can update it ­­

21 MR. FERNSTROM: Well, gee, electric prices

22 have gone up a lot, so I suggest you revisit this one.

23 MS. BURK: Okay.

24 MR. BROOKMAN: Steve.

MR. NADEL: Right. A better source may be I

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1 think it's Electric Power Monthly that EIA publishes

2 every month.

3 MS. BURK: Okay.

4 MR. NADEL: The last time I looked at it,

they were already reporting some data, I think like

6 January 2008 or something. So you can do a 12­month

7 recent months and you'll be just a few months off.

8 MS. BURK: Okay. Great.

9 MR. BROOKMAN: Okay.

MS. BURK: All right. For electricity price

11 trends, DOE used information from EIA's Annual Energy

12 Outlook from 2007. DOE used the electricity price

13 trends for both the reference high­growth and low14 growth cases. The reference cases used for the basic

calculation in the high­growth and low­growth are used

16 as sensitivities. This is an example of the trends

17 shown for each of the three sectors in each of the

18 three cases.

19 MR. FERNSTROM: So, Gary from PG&E again. I

don't think this stands the laugh test. I mean, it

21 would show that in real terms electricity prices aren't

22 going to increase in the next 20 years. I think with

23 all the concern about carbon, you know, carbon trading

24 and so on, I don't think that this is at all realistic.

MR. BROOKMAN: Yes, Steve. Go ahead. It

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1 would be helpful if you could say how you might modify

2 this.

3 MR. NADEL: Okay. Two comments. First,

4 clearly, you should use the most recent AEO.

MS. BURK: Right.

6 MR. NADEL: And the just partially released

7 AEO ­­

8 MS. BURK: 2008.

9 MR. NADEL: ­­ 2008 revised shows a more

realistic trend. It still shows a modest decrease in

11 future prices, but it doesn't show the dramatic

12 decrease that's shown here.

13 MS. BURK: Right.

14 MR. NADEL: The other thing is you may want

to take a basket of other forecasts because EIA is

16 relatively unique in expecting significant price

17 declines in energy in future years compared to most

18 price forecasts.

19 MS. BURK: Okay. Thanks for your comment.

MR. FERNSTROM: So, just one more comment.

21 Gary from PG&E. I wish this were true.

22 (Laughter.)

23 MR. BROOKMAN: Does this fall in the category

24 of woefully inadequate?

(Laughter.)

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1 MR. BROOKMAN: Sorry. Okay.

2 MS. BURK: All right. Now let's talk about

3 discount rates another input to the life­cycle cost

4 analysis. Just to remind you, discount rates are used

to bring operating costs and other costs, like residual

6 value or replacement costs, to present value in the

7 analysis. Discount rates are based on the finance cost

8 of raising funds to purchase products. It involves the

9 cost of any debt incurred to purchase the product or

the opportunity cost of any equity used to purchase the

11 product.

12 For the residential sector, DOE developed a

13 weighted average rate associated with household equity

14 and household debt. Equity ranged from savings bonds,

stocks, and CDs, and debt ranged from credit cards and

16 home equity loans. The primary source of data for this

17 analysis was the Federal Reserve Board Survey of

18 Consumer Finances. DOE looked at this source for a

19 range of years, from 1989 to 2004, to capture all the

economic cycles that may occur over a long period of

21 time. The average discount rate from these sources was

22 found to be 5.6 percent.

23 For the commercial sector, DOE based the

24 discount rates on the weighted average cost of capital

to a firm to obtain debt and equity financing. The

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1 cost of equity was calculated using the Capital Asset

2 Pricing Model. The cost of debt was based on long­term

3 corporate bonds. The average commercial discount rate

4 was found to be 6.2 percent, and the average industrial

discount rate was found to be 7.5 percent.

6 MR. BROOKMAN: Comments? Since discount

7 rates are always an interesting subject. Comments on

8 these before we move on?

9 MR. NADEL: I think the risk premium has gone

up lately.

11 MR. BROOKMAN: Joe, comment? No?

12 MR. HOWLEY: Yeah, they're fine.

13 MR. BROOKMAN: They're fine? Yeah?

14 MR. HOWLEY: I mean, they vary all the time,

but they're reasonable.

16 MR. NADEL: This is Steve. I would note that

17 these are roughly in line with the ­­ first, this ­­ I

18 assume these are real discount rates, not nominal.

19 MS. BURK: Real, yeah.

MR. NADEL: These are roughly in the line

21 with what the utilities are using these days. Maybe

22 they're a little high, but roughly in line.

23 MR. BROOKMAN: Thank you. That's helpful.

24 Okay.

MS. BURK: Okay. Let me move on. So these

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1 are other inputs to the life­cycle cost and payback

2 period analysis. DOE had to estimate lamp lifetime for

3 all of its products. For fluorescent lamps, DOE used

4 lamp lifetimes based on the manufacturing literature

based on a rated life for a three­hour start lamp. DOE

6 used a weighted average of group and spot relamping

7 rates where group replacements were made at 75 percent

8 of the rated life and spot replacements were made at

9 100 percent of the rated life, the end of the life of

the lamp.

11 For incandescent reflector lamps, DOE based

12 the lifetime on the manufacturing literature.

13 The ballast lifetime, as I said before, was

14 based on information from the 2000 ballast rule, which

was approximately 49,000 hours. Again, DOE assumed no

16 repair or maintenance costs. However, DOE does account

17 for lamp replacements in the analysis if the lamp dies

18 before the analysis period ends.

19 The analysis period, as I said before, is the

time span over which the life­cycle cost calculation is

21 calculated. It is based on the longest­lived lamp in a

22 baseline lamp in a product class. The analysis period

23 in years is equal to the life of the lamp in hours

24 divided by the annual operating hours of the lamp for a

given sector or building.

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1 So if a lamp were operating in a closet, it

2 may last 16 years. Then the analysis period would be

3 16 years. But if it were operated in a kitchen, it may

4 only last, say, two years, and the analysis period

would be two years.

6 MR. BROOKMAN: Tom Eckman.

7 MR. ECKMAN: Tom Eckman, Northwest Power and

8 Conservation. Just to clarify the statement that you

9 do include lamp replacement costs. So the operation

and maintenance cost of differential life lamps is

11 included so that the differential is present­valued in

12 there.

13 MS. BURK: Yes.

14 MR. DELASKI: Just to follow up on Tom's

question, I don't follow that because it says that

16 based on the longest­lived lamp in a product class. I

17 think you inserted longest­lived baseline.

18 MS. BURK: Right. That was a mistake in the

19 presentation.

MR. DELASKI: So it's the baseline lamp.

21 MS. BURK: It's the baseline lamp.

22 MR. DELASKI: So, if the replacement lamp

23 lasts longer ­­

24 MS. BURK: Then you just use a residual

value, and there are no replacements within the

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1 analysis period. But in some cases the analysis period

2 may last, say, for the eight­foot, single­pin, slimline

3 lamp, the eight­foot T8 lamp is 15,000 hours. It's the

4 longest­lived lamp in that product class. However,

some of the T12 lamps only last 12,000 hours. So then,

6 for those lamps, the lamp replacement would occur in

7 the analysis period because they would die before the

8 analysis period ends.

9 Does that answer your question? I'm sorry.

MR. DELASKI: It does, I think. But I think

11 the point that I wanted to raise is that the user who

12 has the longer­lived life is getting a benefit in the

13 sense that they have deferred that replacement for a

14 period of time.

MS. BURK: Right.

16 MR. DELASKI: And that's not captured in the

17 analysis, I don't think.

18 MS. GUPTA: It is, because you don't have to

19 ­­

MR. BROOKMAN: Go ahead. Mimi, go ahead.

21 MS. GUPTA: It is, because the shorter­lived

22 lamp you have to purchase again. So you incur another

23 initial cost for that lamp.

24 MS. BURK: And then the residual value. And

that's discounted, so.

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1 MR. DELASKI: Then you count back ­­

2 MS. BURK: Right.

3 MR. DELASKI: ­­ the residual value on the

4 baseline lamp which had been purchased ­­

MS. BURK: Right. But the residual value

6 would occur at a later time, so there is an additional

7 cost of purchase to the shorter­lived lamp. Does that

8 make sense?

9 MR. BROOKMAN: Steve Nadel.

MR. RIVEST: It's all there.

11 MR. NADEL: Just a couple things to clarify

12 on fluorescent lamp life. I'm assuming you used a base

13 lamp, which might be a T12 or T8, which is going to be

14 somewhere around 20,000, but that many of the more

advanced options have 24­ or 30,000 and you just

16 prorate?

17 MS. BURK: Right. That is correct.

18 MR. NADEL: That's one question. The other

19 thing is, what did you do about ballasts and instant

start versus rapid start versus program start, which do

21 affect lamp life?

22 MS. BURK: We did not take that into account

23 in the analysis. However, if anybody can give us input

24 on how ballasts ­­ the operation of a ballast would

affect the lamp lifetime.

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1 MR. BROOKMAN: You would want a distribution

2 based on current ballast sales or something?

3 MS. BURK: Well, we would want how ­­ a rapid

4 start ballast may affect the lifetime versus an instant

start ballast of the lamp.

6 MR. HOWLEY: It's very difficult to analyze

7 because it gets to number of starts, which is

8 impossible to really have any accuracy with. So I

9 think the method that you used is probably reasonably

accurate for lifetimes based on these responses.

11 MR. BROOKMAN: Say it again loudly. It would

12 be accurate?

13 MR. HOWLEY: The method used appears to be

14 reasonably accurate for what you're doing in terms of

taking into account lifetimes. There are many, many

16 variables in the lifetime equation, is what you're

17 hearing here. You have to pick some kind of baseline

18 to analyze on.

19 MR. BROOKMAN: Okay. Steve, were you

finished?

21 MR. NADEL: No. It may well be more

22 complicated, and I agree with Joe. It's so complicated

23 it's not going to make much difference. I was just

24 curious what you had done, just trying to understand.

MR. BROOKMAN: Okay. Additional questions on

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1 this point?

2 (No response.)

3 MR. BROOKMAN: Okay.

4 MS. BURK: All right. Thank you. Now let's

go on to a few of the results of the life­cycle cost

6 analysis. This table displays the results for one of

7 the baselines. Again, we analyzed several different

8 baselines within a product class. This is for the 34­

9 watt T12 baseline lamp, which is in the four­foot,

medium, bi­pin product class. The event analyzed shown

11 here is for the standards­induced retrofit event.

12 So in this event, the baseline system incurs

13 the cost of the lamp, but the standards case systems

14 incur the cost of both the lamp and the ballast.

In this scenario one can see that is not cost

16 effective to replace your magnetic T12 system with an

17 electronic T12 system when you wouldn't have had to

18 otherwise. But it would be cost effective to replace

19 your magnetic T12 system with an electronic T8 system ­

­ with certain electronic T8 systems.

21 The highest life­cycle cost savings for this

22 event occurs at Candidate Standard Level 5. There are

23 three energy­saving options at this event: the 32­watt

24 lamp, the 28­watt lamp, and the 25­watt lamp paired

with their respective ballasts. The most cost

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1 effective option at CSL 5 is for the 28­watt lamp

2 paired with a 0.78 ballast factor ballast.

3 You do see a reduction in mean lumen outputs,

4 approximately 1.3 percent less than that of the

baseline system. However, the life­cycle cost savings

6 is greater than 10 percent of the life­cycle cost of

7 the baseline system.

8 MR. RIVEST: Mike Rivest. Can you go back?

9 An important thing to point out here is

presenting the results of a whole bunch

11 choices at each efficiency level. When

12 to do the national impacts analysis, we

13 weights and estimate what proportion of

14 choose, let's say at CSL 5, the 28­watt

that we're

of potential

it comes time

have to put

people will

lamp versus the

25. That's a key driver, as you can imagine, to the

16 energy savings calculation.

17 MR. BROOKMAN: Okay. Thank you.

18 MS. BURK: The next slide shows the results

19 for the same baseline lamp but for another event, the

ballast failure event. In this event, a lamp and

21 ballast is incurred in both the baseline and standards

22 case systems. The baseline system is an electronic T12

23 system, and if the consumer still wanted to purchase a

24 baseline T12 system they would be forced to purchase an

electronic system because magnetic ballasts would no

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1 longer be available in the year 2012.

2 In the standards case, one can see it is not

3 cost justified to replace that 34­watt T12 electronic

4 system with a more efficient 34­watt T12 lamp on a

lower ballast factor ballast. However, it is cost

6 justified to replace that system with a 32­watt T8

7 system. Again, the highest life­cycle cost savings

8 occur at Candidate Standard Level 5.

9 As Mike referred to earlier, DOE analyzes ­­

puts weights to these results in the national impact

11 analysis. DOE presents all the results for all the

12 events in the life­cycle cost analysis, however DOE

13 chooses not to aggregate these results in this analysis

14 because it would not represent all the options

available to consumers in the real market. For

16 example, non­energy saving options are not ­­ we do not

17 allow that in the life­cycle cost analysis, as well as

18 options that do not maintain lumen output.

19 DOE accounts for all of these options for

many events in the national impact analysis, and this

21 analysis takes place over a 30­year analysis period.

22 MR. BROOKMAN: Comments on these analyses?

23 Yes, Andrew.

24 MR. DELASKI: I'm looking at the ANOPR

document, and in the ANOPR document you ­­ I may not

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1 have found this yet, but you report results of Event 2

2 and Event 3 but you don't report results for Event 4 or

3 5.

4 MS. BURK: Right.

MR. DELASKI: Why is that?

6 MS. BURK: Mike Rivest, you can take this.

7 MR. RIVEST: It was a deliberate attempt at

8 focusing people on the methodologies and the inputs and

9 not so much on the results. Because, obviously, you

know, at this stage we prefer to improve our

11 methodologies and the inputs.

12 So there was that, and then there was just

13 the practical consideration that there are so many

14 results to present, and all of them are in the TSD.

You'll also find that in the notice we

16 aggregate results. Like, here we show them system by

17 system, whereas in the ANOPR we just showed a range for

18 each CSL.

19 MR. DELASKI: Do you expect that in the NOPR

you would show the results for more ­­ the full set of

21 ­­

22 MR. RIVEST: A much more full set. I don't

23 know if they will all be there, but quite possibly. I

24 think they would have to be, frankly.

MR. ECKMAN: The TSD shows the distributions

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1 as well, right?

2 MR. RIVEST: Yes.

3 MR. BROOKMAN: Tom Eckman ­­

4 MR. RIVEST: And the sensitivities.

MR. BROOKMAN: The TSD shows the

6 distributions. Yes, he doesn't need to speak into the

7 mic. I'll speak for him. Thank you, Mike Rivest.

8 Okay. So then ­­

9 MS. BURK: Moving on, so these are the lifecycle costs and some life­cycle cost and payback period

11 results for the incandescent reflector lamp product

12 class. Specifically, this is for the 90­watt PAR 38

13 baseline lamps. Life­cycle cost savings typically

14 increase as the incandescent reflector lamp candidate

standard level rises. The highest life­cycle cost

16 savings occurs for the improved halogen infrared

17 reflector lamp at Candidate Standard Level 3.

18 As Mike Rivest alluded to, additional results

19 for fluorescent lamps and incandescent reflector lamp

life­cycle cost results can be found in the Technical

21 Support Document in Chapter 8, which can be found

22 online.

23 The results of the sensitivities to the life24 cycle cost analysis can also be found online in

Appendix 8B of the Technical Support Document. The

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1 appendix shows results for the Monte Carlo runs, which

2 includes the variability and operating hours and sales

3 tax and electricity prices and discount rates.

4 DOE also analyzed the high and low lamp

prices developed in the product price determination.

6 For incandescent reflector lamps, DOE used the

7 sensitivity developed in the energy use

8 characterization of the high and low operating hours in

9 the residential sector. For fluorescent lamps, there

is a sensitivity that assumes the ballast price is zero

11 in all cases.

12 There are other possible sensitivities that

13 users can use in the life­cycle cost analysis that are

14 not shown. For example, users may be able to select

high and low growth electricity price trends. They can

16 vary the start year in the analysis. They can vary the

17 analysis period as a multiple of the baseline lamp

18 service life and vary the sector for each lamp type.

19 So, DOE seeks comment on any other aspects

related to the life­cycle cost and payback period

21 analysis.

22 MR. BROOKMAN: So as Mike Rivest says, these

23 are illustrative. They are comments ­­ they want your

24 comments on the methodologies, particularly how they

might be enhanced, improved. So that's a good starting

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1 point for additional comment. Yes, Tom Eckman.

2 MR. ECKMAN: Tom Eckman, Northwest Power and

3 Conservation. This is down in the esoterics, but you

4 have this take­back or rebound effect in the analysis

which cites a study from the year 2000. I'll quote.

6 It says, "For 100 percent increase in efficiency, the

7 value of take­back or rebound was between five and 12

8 percent." They're using eight and a half percent.

9 I'm not quite certain that 100 percent increase in

efficiency is in the range of what we're looking at

11 here. So, picking a number that was between five and

12 12 doesn't seem to track. Maybe I'm misreading this.

13 MR. BROOKMAN: Go ahead. Mimi.

14 MS. GUPTA: Well, that's more of a national

impacts issue. We don't take into account the rebound

16 effect in the life­cycle cost analysis.

17 MR. BROOKMAN: Mike Rivest.

18 MR. RIVEST: And to answer your question

19 specifically, that's just to arrive at the elasticity.

So it becomes 8.5 percent. 8.5 is not the number

21 we're using.

22 MR. ECKMAN: It's not an absolute number.

23 MS. BURK: Right.

24 MR. RIVEST: Right.

MR. ECKMAN: Okay.

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1	 MR. BROOKMAN: Other comments on the life2 cycle cost and payback period analyses, particularly

3 the methodologies in play here. Steve Nadel.

4 MR. NADEL: Minor comment. If you go back

two slides to the one that said 90. I believe that's a

6 75­watt because the base case is 75.

7	 MS. BURK: Oh. Very true. Good catch.

8	 MR. BROOKMAN: They are paying attention at

9	 4:20 in the afternoon.

(Laughter.)

11 MR. BROOKMAN: Okay.

12 PARTICIPANT: Let the record show.

13 (Laughter.)

14 MR. BROOKMAN: We're all impressed. We are.

So, additional comments on life­cycle cost and payback

16 period analyses, plural?

17 (No response.)

18 MR. BROOKMAN: Okay. So I did a brief

19 consultation. There is one more slide ­­ why don't you

flash that one ­­ in this segment. I think we've

21 covered the following four issues: operating hours,

22 general service fluorescent lamp energy consumption,

23 life­cycle cost calculation, and installment costs. I

24 think we've delved into all of those. Anybody that has

any additional comments on those, those would be

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1 welcome now.

2 (No response.)

3 MR. BROOKMAN: So then, I consulted with Ron

4 and Linda just about half an hour ago. The agenda as

written says we would adjourn at four. It's now 4:20.

6 We wanted to release anybody that wanted to leave at

7 this point. We've covered one more topic, that being

8 the life­cycle cost analyses and payback.

9 Then we had intended to, today, and I guess

our intention is ­­ that is, if anybody wants to stay,

11 to just stay here and keep going through this content

12 now and work 'til, say, five o'clock. Then ­­ so we

13 get as much of this covered, but also to provide an

14 opportunity, for those of you that were planning on

leaving as the agenda reflects, to leave now.

16 Okay. So there's an option. No harm, no

17 foul. You may leave, for those that wish to leave, but

18 otherwise we're going to keep plugging on, okay? Okay.

19 So, having said that.

MS. BURK: Thank you. So Mimi is going to

21 talk about the national impact analysis.

22 National Impact Analysis

23 Mahima Gupta

24 (PowerPoint presentation.)

MS. GUPTA: All right. So I'm going to talk

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1 about the national impact analysis. So this

2 presentation is composed of both the shipments analysis

3 and the national impact analysis.

4 In the shipments analysis, DOE projects ­­

forecasts lamp shipments and the product mix of the

6 shipments and stock over the analysis period, which is

7 2012 to 2042, in both the base case and the standards

8 case.

9 In the national impact analysis, DOE uses

those shipment forecasts and product mixes to calculate

11 the national energy savings from general service

12 fluorescent and incandescent reflector efficacy

13 standards at different levels. It also estimates the

14 national economic impact on the nation, or net present

value, from general service fluorescent lamps and

16 incandescent reflector lamp efficacy standards.

17 So first, I'm going to discuss a little bit

18 about the general service fluorescent lamp shipments

19 forecast. Here we have a little flow diagram of how

the shipments were forecasted. The first step in

21 calculating shipments was establishing the number of

22 fluorescent lamps in inventory in 2011. Right here.

23 To do that, DOE used NEMA historical shipments from

24 2001 to 2005, extrapolated those shipments to 2011, and

then used an average lamp lifetime to calculate the

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1 number of lamps in the inventory.

2 To establish the average lamp lifetime, DOE

3 used what we call market share matrices, which

4 basically characterize the market shares of the lamp

and ballast inventory in 2011. So this is very much a

6 key input to the national impact analysis, and I'm

7 going to talk more about it in detail later, but I'd

8 just like to highlight that is very important.

9 Then, using an assumption regarding the

number of lamps per system and the product mix, the

11 number of systems in the inventory in 2011, the total

12 lumen output of those systems was calculated, as you

13 can see right here, and here.

14 At this point, shipments were calculated to

meet a lumen demand due to new construction and to

16 replace lamps and ballasts that have retired. A key

17 input into those calculations is the second market

18 share matrix for the ­­ to characterize the market

19 shares of lamp and ballast shipments from 2012 to 2042.

So this is another very important input into our

21 national impacts analysis.

22 So now I'm going to go over some of these

23 inputs in more detail and assumptions that DOE used to

24 calculate their fluorescent lamp shipments.

MR. BROOKMAN: Mike Rivest.

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1 MR. RIVEST: If we go back to the meeting we

2 had for the framework document that we had discussions

3 about how we would forecast the lamps, if we would just

4 essentially go straight to a lamp forecast or if we

would create a ballast inventory model.

6 We found that because of the different events

7 and the completely different economics of each type of

8 event, to be able to keep track of the proportion of

9 lamp replacements versus ballast replacements versus

new construction, we could only do that by creating

11 this ballast inventory model. So that's why this is a

12 little more complicated, probably, than any of us would

13 have liked.

14 Also, the market share matrix here is in

other rules what we call distribution of efficiencies.

16 This is, again, more complex because it's not just a

17 matter of tracking the efficacy of lamps but it's the

18 efficacy of lamps correlated with the ballast on which

19 it's installed. So it's got an extra dimension to it.

This is probably the most important thing in

21 this whole analysis that we need to receive comment on,

22 is those market share and matrices that are shown here

23 in green. That and, obviously, the engineering

24 analysis, the actual selection of ballasts and lamp

pairings.

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1 MR. BROOKMAN: Thanks for that bit of

2 emphasis.

3 MS. GUPTA: So, as I said before, the first

4 step in establishing fluorescent lamp shipments is

calculating the initial stock of fluorescent lamps and

6 ballasts in 2011, and we did that by using the NEMA7 provided historical fluorescent lamp shipment data.

8 DOE assumed that NEMA shipments represent

9 approximately 90 percent of the total fluorescent lamp

shipments in the U.S. and scaled historical shipments

11 accordingly. And then DOE calculated the 2011 lamp

12 stock from average lifetimes of lamps determined by the

13 assumed market shares of the lamp inventory in 2011,

14 which I'll discuss soon.

But these were the lamp stocks calculated for

16 each type of lamp. So you can see the four­foot T8

17 medium bi­pin lamps are overwhelmingly the largest

18 market share. Also important to note is the eight­foot

19 T8 recessed double­contact high output lamps are

extremely small comparatively.

21 MR. BROOKMAN: So before we move on, what

22 about those numbers there? Tom.

23 MR. HOWLEY: This is Joe. I have ­­

24 MR. BROOKMAN: Oh, Joe. Go.

MR. HOWLEY: ­­ a question. It says 2011

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1 NEMA ­­ but NEMA provided data from 2001 to 2005. Did

2 you extrapolate the trends?

3 MS. GUPTA: Right. So, what we did is that

4 we took the 2001 to 2005 data and generally, in most

cases, we took a linear fit of ­­ well, actually, in

6 all cases. Sorry. In all cases we took a linear fit

7 of the historical shipment data and then, based on the

8 average lamp lifetime ­­ for example, if the average

9 lamp lifetime was six years, then we'd sum up six

previous years of shipments from 2011.

11 MR. HOWLEY: So you continued to assume that

12 T8 would increase and T12 would decrease.

13 MS. GUPTA: Exactly.

14 MR. HOWLEY: Okay. Thanks.

MS. GUPTA: Yeah, just a linear fit to

16 historical data.

17 MR. BROOKMAN: Go ahead. Keith.

18 MR. COOK: Keith Cook, Philips. I guess one

19 concern, though, is I'm not sure you would see the

impact for T5s on this shipment and market because T5

21 come in just the last couple years. It had a

22 significant growth rate, though. So it's getting that

23 growth out of something.

24 MR. BROOKMAN: So I'm sure the Department

would welcome those as comments, written comments, if

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1 you can particularly describe what that growth rate is.

2 Is that in the current ­­ in the new NEMA data?

3 MR. HOWLEY: Yeah, we do track T5s, but as a

4 percentage they're still a very small percent of this

market. They're growing fast, as Keith mentioned, but

6 it's off a low base so far.

7 MR. BROOKMAN: Okay. Any additional comments

8 on these numbers as written?

9 (No response.)

MS. GUPTA: All right. So after establishing

11 an initial stock of lamps, DOE made several assumptions

12 to calculate shipments. With regard to four­foot

13 medium bi­pin lamps, or lamp and ballast shipments, in

14 addition to shipping lamps to replace failed lamps DOE

also modeled shipments of new systems, lamp and ballast

16 systems, due to new construction and also to replace

17 failed ballasts.

18 With regard to new construction, DOE created

19 a demand for new construction by modeling an

exponential growth of lumens serviced by four­foot

21 medium bi­pin and eight­foot single­pin slimline lamps.

22 DOE used a 1.6 percent annual growth rate, which it

23 calculated from commercial building floor space growth

24 from the CBECS report.

An important point to note here is that all ­

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1 ­ in the national impact analysis all new construction

2 results in the purchase of a four­foot T8 lamp and

3 ballast system.

4 DOE also modeled shipments of new four­foot

medium bi­pin systems when either a four­foot T12 or a

6 four­foot T8 ballast failed. For both ballast

7 replacement and new construction, DOE assumes that new

8 system shipments are composed entirely of four­foot T8

9 systems as opposed to four­foot T12 systems. This

assumption was made considering the 2000 ballast

11 rulemaking banning of magnetic ballasts.

12 In addition, the four­foot medium bi­pin

13 model currently assumes commercial operating hours and

14 electricity prices.

MR. BROOKMAN: Steve Nadel.

16 MR. NADEL: So if I understand the

17 assumption, it's when an individual ballast fails.

18 Let's say you have a bunch of T12 ballasts. If one

19 fails, they will replace it with a T8 and so they will

either group relamp or mix T8 and T12. That's the

21 assumption?

22 This room, I'll say. This is T8. But let's

23 say it was all T12. If that ballast fails, your

24 assumption is that they will replace it with a T8

ballast ­­

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1 MS. GUPTA: Exactly.

2 MR. NADEL: Okay.

3 MS. GUPTA: I mean ­­ yeah.

4 MR. NADEL: What?

MS. GUPTA: That is the assumption. It's a

6 one­to­one replacement.

7 MR. NADEL: But you're assuming every failed

8 T12 ballast will be replaced with a T8 in the base

9 case.

MS. GUPTA: Yes.

11 MR. NADEL: That may be a little aggressive

12 on the T8 end. I wish it were so. I don't know what

13 your experience has been.

14 MR. BROOKMAN: Well, presumably they reach a

tipping point, right, where they relamp everything.

16 But in the meantime you ­­ go ahead.

17 MS. GUPTA: So you believe ­­ just to

18 clarify, you believe people will be purchasing T12

19 electronic systems to replace their T12 ballast that

has died?

21 MR. NADEL: I would say there will be some of

22 that when individual ballasts fail. Yes, whenever you

23 do a renovation, whenever you do a group reballasting,

24 no question. But, you know, rather than mix T12 and

T8, particularly if they have all halophosphor lamps,

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1 you know, they may not ­­ there will be some T12s just

2 to keep a room looking the same.

3 MS. GUPTA: Okay.

4 MR. NADEL: It may not be a big enough factor

to really affect your calculations. I don't know.

6 MR. BROOKMAN: Joe, yeah.

7 MR. HOWLEY: Yes. The reality is we really

8 aren't sure what people will do once they no longer can

9 get a T12 magnetic ballast. But I would think you're

going to have all three events going on, actually.

11 We've heard of some of that already, where in some

12 cases people just are doing a fixture at a time in a

13 room, which is ­­ and so they do actually mix T12s and

14 T8s.

In other cases, they're doing a room at a

16 time. So if enough lamps are out, they'll let, you

17 know, 30 percent of the lamps go out until finally

18 they'll go in and just replace the whole room, and

19 they'll just do room by room. In other cases there

will be grouper lamps, and then, finally, there will be

21 situations where people try to get by with electronic

22 T12 ballasts.

23 But I think that actually is probably the

24 least likely because the volume of those parts are

going to be very low. The prices are going to be high.

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1 There's going to be a big incentive for them to switch

2 to T8 and electronic because that will be the commodity

3 low price ballast out there.

4 MR. LEWIS: Mimi, when does this start? The

date?

6 MS. GUPTA: 2012.

7 MR. LEWIS: 2012. So it's a ways out still

8 to go. So it's not what is today but a projection as

9 to what may be happening at that time. You've got the

trend line that you've already been plotting showing

11 the increased growth in the T8s and the takeover. So

12 the occurrences ought to be considerably fewer at that

13 point.

14 MR. HOWLEY: Yeah. It appears that you're

estimating maybe 20 percent of the market is T12 at

16 that point. So it's really what's ­­ what do the last

17 20 percent who have absolutely refused to switch to T8

18 do? These are the real laggards that you're finally

19 going to turn over. We're unsure what they're going to

do because they've never done anything.

21 (Laughter.)

22 MR. BROOKMAN: That exchange was Ron followed

23 by Joe. So, Mimi.

24 MS. GUPTA: Yeah. I mean, if we were to

incorporate that effect of T12s being replaced with T12

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1 electronics, we would need information on what portion

2 of people are going to do that in order to ­­

3 MR. BROOKMAN: But, Joe, to reinforce what

4 you just said, your projection is that by ­­ did you

say 2012 ­­ 20 percent will ­­ that's what will be ­­

6 that's what you project will be left. Yeah, okay.

7 MR. HOWLEY: Right.

8 MR. NADEL: This is Steve. Absent any data,

9 yeah, 80 percent T8, 20 percent T12 is roughly about

right.

11 MS. GUPTA: Oh. So what you were saying is

12 that 20 percent of the people will be replacing their

13 T12s with T12s? I thought you were saying that the

14 market share that we presented was about 20 percent.

MR. HOWLEY: Right. What you're saying is by

16 2011 about 20 percent of the installed stock ­­

17 MS. GUPTA: Right.

18 MR. HOWLEY: ­­ will be T12s, and they will

19 be forced by, presumably, possibly, by a rulemaking to

do so.

21 MR. BROOKMAN: Okay.

22 MR. RIVEST: So, really, the information we

23 need is what percentage of people in 2012, when faced

24 with a ballast replacement and no longer have a

magnetic ballast to purchase, what percentage will buy

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1 a T12 electronic versus a T8 electronic. Right now the

2 assumption is zero.

3 MS. GUPTA: Exactly.

4 MR. BROOKMAN: Ron Lewis.

MR. LEWIS: Just to add to that is at that

6 time I'm sure that because there will be fewer of them

7 available that the price differential will change, that

8 people ­­ to buy a magnetic won't be as low of a point

9 anymore because the scarcity factor and people that

need it at that point, and it's been outlawed and not

11 manufactured any longer. You're going to have a lot of

12 different dynamics. So I think the momentum and the

13 inertia is going to be certainly towards the T8.

14 MR. NADEL: Yeah. No, that's already

starting. If I recall, and you guys can tell me if I'm

16 wrong, I believe that a T8 ballast, a basic, generic T8

17 ballast, is generally cheaper than a generic T12

18 ballast.

19 MR. BROOKMAN: Okay. So ­­

MS. GUPTA: All right. So in terms of the

21 base case shipment forecast assumptions for eight­foot

22 single­pin slimline lamps, historical shipments showed

23 minimal growth in that market and actually a decline in

24 the total eight­foot single­pin slimline lamp

shipments. Therefore, DOE did not model any new

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1 construction in that market.

2 In terms of ballast replacement, DOE assumed

3 a 14­year ballast service lifetime and that no new

4 eight­foot T12 single­pin slimline magnetic ballasts

are purchased after 2009 due to the 2000 ballast

6 rulemaking.

7 In addition, as eight­foot T12 single­pin

8 slimline ballasts retire, 10 percent of those systems

9 are replaced with eight­foot T8 systems and 90 percent

are replaced with two­lamp four­foot T8 medium bi­pin

11 lamp and ballast systems. DOE chose those 10 percent

12 and 90 percent numbers to be consistent with the slope

13 of increase of eight­foot T8 lamp shipments.

14 As eight­foot T8 single­pin slimline ballasts

retire, new eight­foot T8 single­pin slimline lamp and

16 ballast systems are purchased as system replacements.

17 Currently, for eight­foot single­pin slimline

18 systems, the model assumes commercial operating hours

19 and electricity prices.

Are there any questions about this slide?

21 MR. BROOKMAN: Steve Nadel.

22 MR. NADEL: Okay. Comment. I agree that

23 there is a trend toward more use of four feet and less

24 of eight­foot. But if I understand, generally

speaking, you need a new fixture to go from ­­ so 90

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1 percent of people ­­

2 MS. GUPTA: No, it's a retrofit ­­

3 MR. NADEL: Oh, they are retrofit with the

4 little double tombstone? Still, it does seem high,

90/10. I would expect more eight­foots than just 10

6 percent.

7 The other thing I'd say is, you're assuming

8 everybody switches from T12 to T8 even though the

9 market is dominated by T12. More so than the four­foot

category, I would expect some people to stick with the

11 T12s.

12 MR. BROOKMAN: Joe.

13 MR. HOWLEY: Joe Howley. I also have a

14 comment. When you do go from an eight­foot to a fourfoot, it's not just a simple lamp and ballast change.

16 I mean, it either is, as Steve said, a new fixture or

17 it's what we call a retrofit kit, where they actually

18 have a kit with additional sockets and features. I

19 guess this question was, was that additional cost put

into the analysis, the fact that it's not just simply a

21 lamp and a ballast.

22 MS. GUPTA: No, that's currently not in the

23 analysis, but if you have information about that,

24 additional costs can be incorporated.

MR. BROOKMAN: The cost of the kit, the cost

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1 of the labor, right?

2 MR. HOWLEY: Yeah. There would be an

3 additional cost either for a new fixture or a kit.

4 It's not just lamps and ballasts. So that should be

put into any kind of conversion model on this.

6 MS. GUPTA: Okay. Thank you.

7 MR. BROOKMAN: Steve.

8 MR. NADEL: We're talking now a base case, so

9 I think including the labor cost is less important

because it is part of the base case. Certainly, if you

11 have a case where the base case is an eight­foot and

12 you're switching to a four­foot, you have to include

13 it.

14 MR. HOWLEY: That's what I'm talking about.

MR. BROOKMAN: Okay.

16 MS. GUPTA: All right. And then in terms of

17 eight­foot recessed double­contact high output, the

18 shipment forecast. This may have to be reevaluated

19 considering some of the comments we got. We assume an

inventory of T12 lamps installed on electronic ballasts

21 right now. Because historical shipments ­­ DOE

22 projects that eight­foot high output shipments will be

23 relatively flat in the future, and DOE assumed that the

24 new construction in this market is serviced by other

technologies, such as T5 lamps.

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1 In addition, as I said earlier ­­ well, I

2 don't know. I don't think I said it earlier. Sorry.

3 (Laughter.)

4 MS. GUPTA: Because T8 lamps accounted for

less than 2 percent of the total eight­foot recessed

6 double­contact high output shipments in 2005, DOE did

7 not model the initial inventory of those lamps.

8 In terms of ballast replacement, DOE used a

9 10­year ballast service lifetime. As eight­foot T12

recessed double­contact high output ballasts retire,

11 new electronic eight­foot T12 recessed double­contact

12 high output lamp and ballast systems are purchased as

13 system replacements.

14 Currently, for

model assumes industrial

16 electricity prices.

17 Any questions?

18 (No response.)

the high output systems, the

operating hours and

19 MS. GUPTA: Okay. So now I'm going to talk a

little bit about the base case market share matrices.

21 I'd like to just flip back to the flow diagram real

22 quick so I can show you where they were. So, back on

23 Slide 4. You can see the green boxes are the market

24 share matrices, and Mike emphasized that these are very

important inputs into our analysis.

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1 So we have two types of market share

2 matrices, one that establishes the product mix of the

3 lamp and ballast inventory in 2011 and one that

4 establishes the product mix of new systems shipped from

2012 to 2042.

6 The shipment model assumes that when a lamp

7 fails it is replaced with that same lamp to maintain

8 the same system throughout that ballast lifetime. But

9 when a ballast fails, it can be shipped with a new

system and maybe a more efficacious system. This is in

11 the base case only.

12 So key inputs into the matrices are the

13 distribution of lamp wattages ­­ for example, what

14 percentage of people are at the 32­watt lamp, the 30­

watt, the 28­, and the 25­watt lamp ­­ the lamp

16 efficacy distributions across CSLs, the ballast factor

17 distributions, how many people are 0.88 ballast, 0.78

18 ballast, 0.75 ballast, any other ballast factors, and

19 the correlation of the three above properties to obtain

total system distributions.

21 Here's kind of a summary of the base case

22 market share matrices that we use for four­foot medium

23 bi­pin lamps. So on the right, or on the left, you can

24 see the four­foot T8 electronic systems market share

matrices. In 2012, you can see that we assume that 90

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1 percent of the people are at 32 watts and 10 percent

2 are at reduced wattages. However, by 2042, we assume

3 that 60 percent of the people will be at 32 watts and

4 40 percent will be at reduced wattages.

In terms of lamp efficacy, you can see that

6 for four­foot T8s we assume most of the people are at

7 the lower efficacies and that shifts in 2042. In terms

8 of ballast factor, we have 90 percent of the people at

9 a 0.88 ballast factor. We see a shift to lower ballast

factors by 2042.

11 DOE tried to establish these based on

12 manufacturer interviews and availability of product in

13 catalogues.

14 For T12 lamps, DOE assumed that 40 percent ­­

30 percent of people would be at the 40­watt in 2012

16 and 70 percent of the people would be at a 34­watt

17 lamp. You can see the efficacy distributions here.

18 They're weighted toward the baseline lamp.

19 So you can see complete market share matrices

for the four­foot medium bi­pin base ­­ four­foot

21 medium bi­pin lamps and ballast systems in Chapter 9 of

22 the ANOPR TSD.

23 MR. BROOKMAN: Mike Rivest.

24 MR. RIVEST: I just want to point out that

this is uncorrelated data at this point. This is the

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1 best information we have for 2012. We've extrapolated

2 an improvement in efficiency to 2042 and that's part of

3 our base case, but then we have to go the extra step of

4 correlating ballast and ballast factor.

So if you were to comment on nothing else, if

6 you could comment on the first slide, that would

7 already be an improvement. But the ideal one to

8 comment on would be the correlated market share matrix.

9 MS. GUPTA: Right. This slide is what Mike

is referring to. This is an actual market share matrix

11 that you can find in the TSD.

12 As you can see here, this is kind of showing

13 the characteristics of our system. So we have like a

14	 0.88 ballast factor ballast, and we show, well, you can

have a 32­watt lamp with an efficacy of 86.2 lumens per

16 watt. We assume that 43 percent of the inventory is at

17 that particular system.

18 You see all the systems that we use. We

19 basically pair every lamp generated in the engineering

analysis with the three ballast factors.

21 MR. BROOKMAN: Joe.

22 MR. HOWLEY: Yes. Mike, did you use NEMA

23 data for the 32­, 30­, and 28­watt split as well?

24 MR. RIVEST: I don't think there was NEMA

data, official NEMA data. We ­­

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1 MS. GUPTA: Yeah. There was no official NEMA

2 data. It was a combination of information that we got

3 from interviews with manufacturers and just taking an

4 inventory of how many products were available of the

different types. So we could definitely do better on

6 that information.

7 MR. HOWLEY: We can look at that and see how

8 close you are.

9 MR. BROOKMAN: Paul.

MR. WALITSKY: The one that popped out at me

11 was zero percent for the 25­watt in 2012 when there are

12 thousands of lamps being sol

13 d now in 2008. So that number is going to be a lot

14 higher than zero.

MS. GUPTA: Okay.

16 MR. WALITSKY: I have no guess. I leave that

17 to Joe and NEMA to guess where that number is, but

18 certainly it's not zero. My guess is it will be a lot

19 higher in 2012.

The other part of the comment is, I notice

21 later on that as it would play out you have emerging

22 technology for infrared lamp but not ­­ for the

23 incandescent reflector but not for fluorescent. My

24 guess is sometime down the road you're going to see

LEDs in the ceiling replacing four­foots, sometimes

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1 well before 2042. So you're going to have to take that

2 into account like you did for incandescents into this.

3 Just go down the hall and talk to Jim

4 Broderick and see what his estimates are because he has

them.

6 MR. RIVEST: Okay.

7 MR. BROOKMAN: It's a ways out. Steve Nadel.

8 MR. NADEL: A couple of comments on this

9 matrix, some initial comments at least. One, my

understanding is while the 30­watt lamp was the first

11 of the reduced wattage T8s that it's mostly being

12 replaced in terms of sales with the more efficient

13 ones, the 28s or 25s. It was kind of a first14 generation energy saver.

So I'd would be surprised if the 30s ­­ I'm

16 not saying they'll go to zero, but they won't be quite

17 as robust as you're showing. That's one comment.

18 Two, in terms of ballast factors, I recall ­­

19 I don't remember the exact numbers. You have a 0.78,

which is a very common one. My understanding is more

21 manufacturers are coming out with somewhat lower

22 ballast factors. I recall a 0.7 from one manufacturer,

23 0.68, 0.69. I don't think the 0.75 is that common.

24 There will be a bit more of a jump for that category.

I can look up some data, you can look up some data on

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1 what that might be.

2 The third one, and this one may go beyond

3 what you want to do, is also the 1.18 ballast factors.

4 What those allow is sometimes using two­lamp fixtures

instead of three­lamp fixtures or one­lamp fixtures

6 instead of two­lamp fixtures. Are you going to get

7 into that at all? I know those are going up to a

8 significant extent because of those applications.

9 MS. GUPTA: Yeah. The approach we took in

the national impact analysis was similar to what we

11 took in the engineering and the LCC, in which we tried

12 to model the average system in terms of lamps per

13 ballast. Okay.

14 MR. BROOKMAN: Any additional comments?

MS. GUPTA: So this is what we want you guys

16 to fill out.

17 MR. LEWIS: This is what they have ­­ show

18 them in the TSD.

19 MS. GUPTA: Oh yeah.

MR. LEWIS: Table 933. Chapter 9.

21 MR. BROOKMAN: Oh, thank you.

22 MS. GUPTA: So those table numbers are ­­

23 MR. BROOKMAN: Chapter 9. Mike Rivest.

24 MR. RIVEST: I think, again, to try to

simplify what comments you provide and how you provide

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1 them, filling in the matrix is ideal for us. It

2 minimizes our work. But really, what that matrix is

3 then doing is it's collapsing that into a typical

4 system, an average system base case in that year with

an after­standards average system in that same year.

6 So if one could go right to that answer and

7 say, you know, the standard going from CSL 1 to CSL 3

8 results in a 5­watt system improvement, that would be

9 helpful as well.

MS. GUPTA: Yeah. If we were to get the

11 aggregated data, then we would need the price

12 associated with the average system.

13 MR. RIVEST: I didn't say anything.

14 MR. BROOKMAN: Okay.

MS. GUPTA: So, on to the eight­foot, single16 pin, slimline base case market share matrices. We see

17 a similar thing depicted here. Here we make an

18 assumption that 100 percent of eight­foot T8 systems in

19 2012 are at 59 watts and we see a shift toward the

reduced wattages by 2042. Again, the lamp efficacies,

21 we see a shift toward higher lamp efficacies by 2042

22 and to lower ballast factors.

23 In terms of the T12 slimline magnetic

24 systems, we have 60 ­­ two­thirds of the inventory at

75 watts and one­third at 60 watts and the shown

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1 efficacy distributions.

2 Does anyone have any comments or questions on

3 the eight­foot slimline efficacy distributions or

4 wattage distributions or ballast factor?

(No response.)

6 MS. GUPTA: All right.

7 MR. LEWIS: It's just about five o'clock.

8 I'm guessing that you're going to want to get to Slide

9 38, which is the end of this section. So we ought to

do a check with everybody where they stand. I don't

11 want to presume that anybody is ­­ we've already asked

12 you to stay a little bit later today. There were

13 people that wanted to see us conclude today.

14 If there's anybody that needs to leave or if

there are a majority of you who think that ­­

16 MR. BROOKMAN: Ron, you're covering up the

17 microphone.

18 MR. LEWIS: If the majority of you think that

19 you've had enough fun for one day. We're in the midst

­­ you know, we're a third of the way into one section.

21 It would be hard to just pick up in that section. So

22 my instinct is to carry to the end of this section and

23 then pick up in the morning, if everybody's okay with

24 that, with the understanding that anybody that has to

leave or wants to leave at this point because they have

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1 just endured as much as they can, feel free to do that.

2 MR. RIVEST: Also, a thing to point out is

3 that if we can get through this section what comes

4 tomorrow is a description of what will be done for the

NOPR. So it's less ­­ it requires less comment and

6 it's more familiar to a lot of people, whereas these

7 next 20 slides are very important.

8 MR. BROOKMAN: Yeah, Steve Nadel.

9 MR. NADEL: That sounds good, plowing on.

The one thing, if we can leave three minutes at the

11 end. Since I won't be here tomorrow, I had one

12 question about the ­­ laying the groundwork for that.

13 MR. BROOKMAN: Sure. Okay. So then we're

14 going to press on. Anybody that needs to leave, please

feel free. Okay.

16 MS. GUPTA: Okay. So if there's no comments

17 on the eight­foot slimline market share matrix inputs,

18 you can find the full market share matrices in Chapter

19 9 of the ANOPR TSD. I'll just move on.

Here's the eight­foot, recessed, double21 contact, high­output market share matrix inputs. As

22 you can see, we have about 60 percent of our 2012

23 shipment distribution at the 110­watt lamp, 40 percent

24 at the reduced wattage, 95­watt lamp, and we see a

shift towards the 95­watt lamp with ­­ by 2042.

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1 In terms of lamp efficacy, we are heavily

2 weighted towards the baseline lamp in 2012 and then we

3 shift towards higher efficacy lamps. In terms of

4 ballast factors, we assume electronic ballast factors

of 0.90, 0.89, and 0.88 and pretty much equal

6 distribution of those. Those were the available

7 ballast factors ­­ commercially available ballast

8 factors that we found. So that's why we don't see much

9 variation.

Any questions?

11 (No response.)

12 MS. GUPTA: All right. So let's take a look

13 at some of our shipment results. This is a plot of the

14 four­foot, medium, bi­pin shipment results. As you can

see, the four­foot T8 shipments are growing due to new

16 construction and retrofitting of four­foot T12 and some

17 eight­foot T12 single­pin slimline systems.

18 You can also see that the four­foot T12

19 medium bi­pin lamps reach zero shipments by 2022, and

that's because we assume that since no new T12 systems

21 are shipped, eventually no T12 lamps will need to be

22 shipped.

23 As an output based on certain lifetimes that

24 we use in our model and new construction growth rates,

on average lamp replacement constitutes about 63

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1 percent of shipments, ballast replacement constitutes

2 30 percent of shipments, and new construction, 7

3 percent of shipments.

4 For eight­foot single­pin slimline ­­

MR. BROOKMAN: Can we just pause for a

6 moment? I would really like to validate that if we

7 could. New construction, seven percent; ballast

8 replacement, 30; lamp replacement, 63 percent. What do

9 you think? Joe, yeah?

MR. HOWLEY: It seems reasonable. Something

11 in that range. The new construction is probably about

12 right. The ballast replacement, I guess, is the one

13 that probably has the most ­­

14 MR. BROOKMAN: Variability?

MR. HOWLEY: ­­ variability associated with

16 it.

17 MR. BROOKMAN: Keith, you say yes, also?

18 MR. COOK: Yeah, I would agree with that.

19 MR. BROOKMAN: Okay. Thank you.

MS. GUPTA: Perfect. All right. Eight­foot

21 single­pin slimline. All right. So for eight­foot

22 single­pin slimline shipments, we see that the eight23 foot T8 single­pin slimline shipments show a slight

24 growth due to the retrofitting of some of the eightfoot T12 lamp and ballast systems. We see a continuous

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1 decline of the eight­foot T12 lamp shipments. Again

2 due to the banning of magnetic ballasts, we assume that

3 eventually those shipments are going to go to zero

4 because there will be no ballast on which to install

those lamps.

6 And for that lamp, the model outputs

7 approximately 78 percent of lamp shipments are due to

8 lamp replacement and 22 percent of lamp shipments are

9 due to ballast replacement.

Any comments?

11 (No response.)

12 MS. GUPTA: And finally, for the eight­foot,

13 recessed, double­contact, high output shipments, as I

14 said earlier, we model the eight­foot T12 shipments as

being flat from 2012 to 2042. We don't model the

16 initial stock of eight­foot T8 recessed, double17 contact, high output systems.

18 The outputs of that model show that lamp

19 shipments due to ballast replacement are approximately

one­fifth of the total shipments and four­fifths are

21 lamp replacement shipments. Okay.

22 MR. BROOKMAN: People are going to speak up

23 if they think significantly differently.

24 MS. GUPTA: Yeah. I'm moving on to the

standards case, so if anyone wants to say anything

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1 about the base case, now would be a good time.

2 (No response.)

3 MS. GUPTA: Okay. So in terms of the

4 standards case shipment methodology, there are two

major areas that we differ from the base case. One of

6 them is that instead of using a market share matrix

7 that characterizes the product mix of shipments from

8 2012 to 2042 that is in the base case, we use a

9 standards case market share matrix.

A second important aspect is that we

11 introduce additional standards­induced retrofits of T12

12 systems in the standards case. I'll talk a little bit

13 more about that.

14 So, as I just said, in the standards case

shipment methodology we developed standards case market

16 share matrices. To do that, we used several shipment

17 scenarios, or two shipment scenarios to characterize

18 how consumers will change their purchase decisions with

19 standards.

The standards case market share matrices

21 generally show a movement to higher efficacy lamps and

22 alternate ballast factor ballasts. We have separate

23 standards case market share matrices for consumers just

24 purchasing a lamp for a lamp replacement and a separate

one for consumers purchasing new lamp and ballast

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1 systems.

2 A second part of the standards case

3 methodology is to incorporate standards­induced

4 retrofits. DOE assumes that the increased first cost

of higher efficacy four­foot T12 medium bi­pin and

6 eight­foot T12 single­pin lamps will result in

7 additional voluntary retrofits in the standards case.

8 In addition, we also incorporate mandatory retrofits of

9 T12 systems due to ­­ if you go to a standard level

that is above the level at which a T12 lamp is

11 available. So, using those two inputs, we could

12 recalculate the shipments and stock product mixes.

13 Now I'm going to just talk a little bit about

14 the standards case shipment scenarios. Our standards

case shipment scenarios consider lamp price, system

16 lumen output, and system energy consumption as drivers

17 for consumer purchases. We have two scenarios. One is

18 a roll­up scenario and one is a shift scenario.

19 The roll­up scenario represents a lower bound

of energy savings, and in that scenario only consumers

21 purchasing below the candidate standard level will

22 change their purchase decisions in the standards case.

23 These consumers will purchase the lowest first cost

24 lamp option available.

In the shift scenario, which represents the

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1 upper bound of our energy savings, all consumers

2 reevaluate their lamp and ballast decisions. Consumers

3 currently purchasing the lowest efficacy option

4 continue to purchase the lowest first cost standardscompliant lamp, but all other consumers who are

6 purchasing above the lowest efficacy option purchase

7 the lowest first cost energy­saving lamp ­­ or, energy8 saving option.

9 So, a second effect that we model in the

standards case fluorescent lamp shipments model is the

11 standards case retrofits. As I said before, we assume

12 that an increased efficacy standard will require ­­

13 will result in an increased T12 lamp price and that

14 will cause some consumers to retrofit their T12 system

before it retires and purchase a T8 system instead. We

16 apply this to four­foot T12 systems and eight­foot T12

17 single­pin slimline systems.

18 Right now, as inputs into our model, we

19 assume at CSL 1, 10 percent of consumers will ­­ 10

percent of the remaining stock of T12 systems will

21 retrofit per year. CSL 2, it's 20 percent; CSL 3, 30

22 percent, and so on. So this is definitely an input

23 that we need your input ­­ your comment on and would

24 appreciate ­­

MR. BROOKMAN: Keith.

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1 MR. COOK: Yeah. It was not clear to me,

2 though, how much of this voluntary retrofit was due to

3 other enticements, utility rebates, et cetera, and

4 whether or not those will continue going forward.

MS. GUPTA: Well, I think these are just the

6 incremental between the standards case and base case.

7 So this 10 percent, none of it is due to utility

8 rebates because it would just ­­ because that would be

9 incorporated in the base case.

MR. RIVEST: Mike Rivest. One way to think

11 about this is, so a ballast fails and they voluntarily

12 replace every ballast in the room. So it's like an

13 acceleration of the turnover of the T12 stock due to

14 the higher price of the T12 lamp. So we try to model

that acceleration.

16 MS. GUPTA: I'm sorry. So you were ­­ were

17 you just saying that the utility rebates would be

18 particularly effective in the standards case?

19 MR. COOK: Yeah, that's what I think drives a

lot of the voluntary retrofit, is they have other

21 enticements to make the change­out.

22 MS. GUPTA: But that's something that happens

23 in both the base case and standards case, right?

24 MR. COOK: Base case and standards ­­ what

I'm saying is, you're right, it doesn't affect the base

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1 case, but you would see it in the standards case. It's

2 what allows them to go to the higher, more ­­ it gets

3 back to the original problem. The initial cost on the

4 higher levels is cost prohibitive, typically.

MR. BROOKMAN: The standards case might

6 motivate the utilities to go higher and faster?

7 MR. COOK: Correct.

8 MR. BROOKMAN: Go ahead, Gary.

9 MR. FERNSTROM: This is Gary from PG&E. I

think I missed that point. Could you restate that?

11 MR. COOK: Well, it's the same thing we just

12 went through with CFLs. I mean, for years and years

13 they have hardly gone anywhere, and now PG&E, for

14 instance, is subsidizing the cost of CFLs in

California. We've got Wal­Mart subsidizing the cost.

16 All of a sudden, you know, we're seeing a 20 percent

17 per year increase in CFLs. Everybody is saying, well,

18 great, you know, everybody is catching on to the energy

19 efficiency. I don't know that that's true. You know,

it's being subsidized.

21 MR. BROOKMAN: The price has come down.

22 MR. COOK: Yeah.

23 MR. FERNSTROM: Well, I mean, I'd like to

24 think that all those utilities and others around the

country that have education and incentive programs are

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1 having a big impact, but I've got to tell you, PG&E has

2 been providing incentives for CFLs for 20 years. It's

3 just, you know, kind of recently we've seen a big

4 increase.

So I think the attribution has to go, you

6 know, not only to the utilities but the national

7 attention on global climate change, the increased

8 availability of these products, and a lot of other

9 things.

MR. BROOKMAN: Has the price continued to

11 decline for 20 years?

12 MR. FERNSTROM: Yeah. Slowly at first

13 MR. BROOKMAN: Yeah, yes. Very ­­ yeah,

14 right. Yeah. I just ­­

MR. FERNSTROM: I mean, the first products

16 that we featured had a retail cost of about $28, and we

17 subsidized them and sold them for $9.

18 MR. BROOKMAN: Wow.

19 MR. FERNSTROM: But, you know, huge

difference between then and now.

21 MR. BROOKMAN: Yeah, right. Okay. So,

22 thanks for your point.

23 MS. ANDERSON: I have a question because a

24 lot of the T12 ­­

MR. BROOKMAN: Please say your name again and

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1 get the microphone close. Thank you.

2 MS. ANDERSON: Susan Anderson, Osram

3 Sylvania.

4 MR. BROOKMAN: Thank you.

MS. ANDERSON: A lot of the T12 market is

6 residential. The chief magnetic residential ballast is

7 allowed in the current ballast ruling. You're talking

8 about T12s going away by 2022. I mean, if those

9 ballasts are still out there ­­

MR. BROOKMAN: If they're still on the

11 market, it's to be ­­ to serve the replacement, right?

12 Is that ­­

13 MS. ANDERSON: Yeah, they're not covered.

14 They're allowed. So, I mean, there's a condition there

where we're still going to be selling T12 systems,

16 lamps and ballasts.

17 MR. HOWLEY: Joe Howley. You know, that

18 point also brings up kind of an important

19 consideration. Right now, perhaps a third of the

market as we sit here in 2007, 2008, is T12 versus T8.

21 Of that remaining third of T12 lamps we sell in the

22 four­foot fluorescent sector, a fairly significant

23 percentage now is going into the residential sector of

24 that remaining bit.

So that would also suggest, if you're going

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1 to model who's using T12 lamps right now and who would

2 be most affected, it would be perhaps, especially if

3 you went to one of these higher levels where the T12

4 lamp simply wasn't available anymore, it would affect

your residential consumer who runs these about a

6 thousand hours a year.

7 Any analysis on this should definitely

8 consider the effects because by 2012, if the market is

9 20 percent T12 like we're projecting, or I think you

had about 18 percent based on that chart, over half of

11 those are going to be residential consumers. So this

12 regulation is going to affect the residential consumer

13 burning these a thousand hours a year. That has to be

14 modeled into your cost analysis in terms of is that

cost effective for them.

16 MR. FERNSTROM: This is Gary from PG&E. Let

17 me just make a comment on that. I have a 44­year­old

18 house that had a T12 fluorescent four­lamp fixture in

19 the kitchen for all of those 44 years. This last year

I replaced it with a T8 fixture with electronic

21 ballast.

22 MR. BROOKMAN: I bet you didn't incur any

23 labor costs, did you.

24 (Laughter.)

MS. GUPTA: A little round of applause.

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1 MR. FERNSTROM: I incurred a lot of labor

2 cost being as I did it myself.

3 (Laughter.)

4 MR. BROOKMAN: That's what I was counting on.

MR. FERNSTROM: But the point I want to make

6 is, there's two ways you can look at that. You can

7 say, well, you know, those poor customers are going to

8 be faced with the absence of this lamp in the market

9 and that's going to impose a tremendous hardship on

them. On the other hand, I've got to tell you that my

11 replacement with the new T8 electronic ballast fixture

12 was highly cost effective.

13 So if we look at it from a life­cycle cost

14 point of view, I should have done it years ago. If a

regulation can help me toward that decision, that's

16 probably a good thing.

17 MR. BROOKMAN: Do you think you're a normal

18 consumer in that respect?

19 MR. FERNSTROM: I am. I am a normal consumer

because I waited the 44 years to do it.

21 (Laughter.)

22 PARTICIPANT: And, did you get a rebate or a

23 subsidy from your local utility?

24 MR. FERNSTROM: No.

(Laughter.)

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1 MS. GUPTA: Well, if we were to incorporate

2 these residential consumers, we would definitely need

3 some detailed information on what percentage of T12s

4 are in the residential sector.

MR. HOWLEY: Okay. We could provide further

6 comment on that, but I think ­­ this is just a factual

7 matter ­­ that you probably did this analysis based

8 solely on a commercial customer, and that is a mistake.

9 You really need to consider the impact on the

residential customer, who is going to be most of the

11 market come 2012.

12 MR. BROOKMAN: Thank you. Susan, thanks for

13 raising that point.

14 MR. FERNSTROM: Gary again. If I could add

something to Joe's point, it was only in the last few

16 years that California has taken a real strong step

17 toward mandating at least in new construction CFLs in

18 residential construction with dedicated pin bases.

19 There have got to be a lot of T12s with magnetic

ballasts in homes in California because fluorescent

21 lighting has been required for 30 years. Virtually all

22 of that is T12 and magnetic ballast.

23 MR. BROOKMAN: Thank you. Ron Lewis.

24 MR. LEWIS: I've got just enough memory left

to get me in trouble here. Was there not a low wattage

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1 lamp that was used in residential settings as well as

2 you've got a low power factor ballast that's out there?

3 They're not the same equipment that's used in the

4 commercial or industrial setting. Are they not unique

and identifiable for the most part for the residential

6 market? Like in the shop light ­­

7 MR. HOWLEY: Yeah. You're referring to the ­­

8 MR. BROOKMAN: Joe, yeah. Go ahead.

9 MR. LEWIS: ­­ the top 10 design criteria are

price, price, price, and price?

11 MR. HOWLEY: You're referring to the 25­watt

12 shop light lamp that was for the 1992 Energy Policy Act

13 rulemaking. That was defined in a specific way,

14 recognizing that would generally run on a consumer shop

light low power factor ballast. It was rated that way.

16 We sell both types today. The shop light

17 lamp is sold but also what we call the resi­lights, or

18 the kitchen and bath lights, which are basically

19 commercial lamps, are sold as well. But it is

essentially, from a manufacturing perspective, a four21 foot T12 lamp. So it really isn't that different from

22 a manufacturing perspective.

23 MR. BROOKMAN: Go ahead, Mike Rivest.

24 MR. RIVEST: If we were to have information

on the shipments to the residential sector, it would be

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1 helpful to know if these particular lamps are included

2 or not within the previous estimates and any new

3 estimates.

4 MR. HOWLEY: They were included in the

previous estimates.

6 MR. RIVEST: Oh, they were?

7 MR. HOWLEY: It was in the entire market. We

8 didn't try to separate out any of these other types.

9 That's the way NEMA collects the data, so that's ­­

MR. RIVEST: Okay.

11 MR. BROOKMAN: Susan.

12 MS. ANDERSON: Yeah, I wanted to make one

13 other comment. That 25­watt lamp, by the way, is

14 included. We have supported including it in the

standards going forward. That's that 25­watt T12.

16 But the other thing I wanted to point out; in

17 the residential market you're seeing fixtures in the

18 DIYs that have electronic ballasts in them that they

19 say will operate either T8 or T12. So those are

perpetuating T12s in the marketplace, and that's

21 something else ­­ they're electronic ballasts, but they

22 market them. They'll put a pallet of fixtures in a

23 stack and they'll put a pallet of T12 lamps on one side

24 and a pallet of T8 lamps on the other.

MR. BROOKMAN: Okay. Steve Nadel.

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1 MR. NADEL: Yeah. I would note that probably

2 just in the last year or two I've started seeing a lot

3 more T8 shop lights coming out, all of a sudden, with

4 electronic ballasts. That's ­­ the prices have come

down. I mean, they're all from China or other Asian

6 countries, so that's becoming more common and will, you

7 know, start to predominate certainly by 2042 if not

8 well before.

9 The other comment is on this slide, back to

this. I agree that standards will accelerate retrofit.

11 That looks awfully ambitious. All of a sudden ­­ you

12 do Candidate Standard Level 5 in the next year and half

13 the people will voluntarily retrofit? I wish it were

14 the case, but I'm not sure I believe that.

MR. BROOKMAN: What would the numbers be,

16 Steve? What do you think?

17 MR. NADEL: I'd divide them at least by two,

18 but I'm making an educated guess. I don't know.

19 MR. BROOKMAN: Is there any ­­ is there

experience from previous rulemakings that's relevant

21 here?

22 MR. HOWLEY: This is Joe. I think Steve has

23 somewhat of a point that 50 percent ­­ because the

24 lamps don't burn out that fast. It's unlikely that 50

percent of the market would have to change lamps in one

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1 year. Even if you assume let's say a five­year life,

2 probably your high end is going to be 20, 25 percent,

3 even on Standard Level 5, because that's simply the

4 number of lamps that would burn out in a year.

Your range ­­ 10 percent is probably not bad

6 to start with, but your top end is probably no more

7 than 25 percent, and then just range it up between 1

8 and 5 between 10 and 25 percent.

9 MR. BROOKMAN: Okay.

MR. HOWLEY: Fifty percent is probably very

11 aggressive.

12 MS. GUPTA: Okay. Thanks. Joe, you actually

13 bring up a good point for the next bullet on the slide,

14 which refers to mandatory T12 ballast retrofit, which

is done at the time of lamp failure. At certain CSLs,

16 at CSLs 4 and 5, no T12 lamps are available to

17 purchase. So when their existing T12 lamp dies, they

18 retrofit their system. So, yeah, we have 50 percent of

19 the people in the first year just doing it because

they're smart, but then when that lamp dies, for the

21 remaining people, they'll retrofit their system.

22 MR. BROOKMAN: Okay. We're moving on. It's

23 almost 5:30.

24 MS. GUPTA: So, do we ­­ we don't want to

stop at the comments?

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1 MR. BROOKMAN: Oh, well, I thought people

2 were giving comments as we went.

3 MS. GUPTA: Are there any other, further

4 comments?

MR. BROOKMAN: Well, actually, that's what

6 you want. Please review this list. See if there's

7 anything else you wish to say about methodology and

8 data sources, fluorescent base case and standards case

9 market share matrices, which I thought Mike did a good

job of describing, fluorescent base case shipment

11 forecasts, and the other two. Additional comments on

12 those?

13 (No response.)

14 MS. GUPTA: All right. So the next topic I'm

going to be talking about is the incandescent reflector

16 lamp base case shipment methodology.

17 So, first, DOE used NEMA historical shipments

18 of IRL to estimate the historical shipments of covered

19 lamps, taking into account the definition of

incandescent reflector lamps in EISA 2007 and various

21 exemptions for those lamps ­­ or, various exemptions

22 for certain IRL. This also includes taking into

23 account non­NEMA members, trying to scale up those

24 shipments a bit.

DOE then extrapolated the shipments to 2011,

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1 and then, using the product mix of the inventory, DOE

2 establishes the lamp inventory in 2011. Then, using

3 assumptions regarding new construction and the

4 penetration of emerging technologies, DOE forecasts the

number of lamps in inventory from 2012 to 2042. Then,

6 finally, by establishing the product mix of the

7 inventory over the analysis period and tracking the

8 retirement of lamps, DOE calculates total IRL

9 shipments.

Similar to the fluorescent lamp shipment

11 model, the first step was to establish the 2011 lamp

12 stock. NEMA provided historical shipments for non13 halogen and halogen IRL. When I say "non­halogen," I

14 mean incandescent technology.

So DOE made several assumptions in order to

16 get to a covered lamp shipments number. We assumed

17 that NEMA shipments represent 85 percent of total IRL

18 shipments. DOE estimated that EISA 2007 exempted

19 approximately 60 percent of incandescent reflector

lamps. We assumed that, of non­halogen shipments or

21 incandescent shipments, 33 percent serve the commercial

22 sector and 67 percent serve the residential sector. Of

23 halogen shipments, 60 percent serve the commercial

24 sector and 40 percent serve the residential sector.

All of those assumptions combined, plus a

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1 lifetime assumed by our market share matrices, we

2 achieve an installed stock of covered IRL in 2011 to be

3 approximately 300 million lamps in the residential

4 sector and 77 million lamps in the commercial sector.

Any comments?

6 (No response.)

7 MS. GUPTA: Then, as stated earlier, the next

8 step in the IRL shipment model is to forecast the

9 number of lamps in the IRL stock from 2012 to 2042. To

do that, DOE takes into account two phenomena: new

11 construction and the penetration of emerging

12 technologies.

13 To account for new construction, DOE applies

14 an exponential growth to the number of IRL sockets in

2011 based on the CBECS and RECS building floor space

16 growth. So, in the residential sector, we have a 1.3

17 percent growth and in the commercial sector we see a

18 1.6 percent growth.

19 Historical annual growth of IRL stock

calculated from historical shipments is estimated to be

21 approximately eight to 10 percent. However, DOE

22 believes that this growth may be unsustainable and uses

23 the building floor space growth to estimate new

24 construction instead.

Another important trend that DOE takes into

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1 consideration in developing the IRL stock projection is

2 penetration of emerging technologies. DOE assumes that

3 technology such as CFLs, ceramic metal halide, LEDs,

4 will penetrate the market. For the ANOPR, DOE

estimates that 50 percent of the 2042 IRL sockets will

6 be emerging technologies.

7 MR. FERNSTROM: This is Gary from PG&E. I

8 have a quick comment on that. Work done by the

9 California Lighting Technology Center shows that a

large number of California homes have cans in them now

11 in the order of 40 cans per home. I think what you're

12 doing is extrapolating, you know, what you think the

13 current market share of cans is for growth, and I think

14 the market share of cans has increased.

So you might want to talk to the CLTC and see

16 if you can get some information on that. I don't know

17 whether that's a California effect or a national

18 effect, but I would guess that across the country the

19 share of cans is increasing.

MR. BROOKMAN: Steve Nadel.

21 MR. NADEL: Yes. Along those same lines, I

22 think RLSW did a study, as did ­­ Home Group. I can't

23 remember which one ­­ where they actually trace the

24 number of cans in homes by home age, and yet the newer

homes have more. So just to assume, you know, that it

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1 grows with the stock is probably a little too

2 conservative.

3 MR. BROOKMAN: Okay.

4 MS. GUPTA: Okay.

MR. NADEL: To add one more thing, it would

6 be great if these sockets get filled with something

7 other than an incandescent reflector lamp, like a

8 ceramic metal halide or solid state lighting.

9 MS. GUPTA: Well, that 50 percent assumption

is definitely something that we'd like comment on, if

11 anyone has more information.

12 MR. BROOKMAN: Andrew.

13 MR. DELASKI: On that assumption, you're

14 assuming that number is the same in the base case and

the standards case?

16 MS. GUPTA: Exactly. It's just an inventory

17 subtraction and the inventory of covered IRL is the

18 same in the base case and the standards case.

19 MR. DELASKI: You're subtracting out 60

percent up front because ­­ is outside the scope.

21 MS. GUPTA: Right.

22 MR. DELASKI: ­­ percent on the back end.

23 MS. GUPTA: Yeah, yeah. So here you can see

24 basically, considering our 2011 stock that we

calculated of covered IRL, the upper profile would ­­

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1 increases due to new construction growth, and then we

2 decrease the total stock by 50 percent in 2042. So the

3 blue area shows the stock of IRL off of which we're

4 calculating our national energy savings and on which we

base our shipments.

6 MR. RIVEST: Mike Rivest. If I understand

7 the comment about the cans, it would be that our growth

8 rate isn't sufficient because we've only got 1.6

9 percent and maybe the cans are penetrating existing

homes.

11 MR. FERNSTROM: Gary from PG&E. That's

12 precisely the point. One thought with emerging

13 technologies; practically all of these cans are on

14 dimmer circuits. So if our new technologies are going

to grow to that market share, they're going to have to

16 be dimming­compatible.

17 MR. BROOKMAN: Yes, please. Pam.

18 MS. HORNER: One comment which stems back.

19 I've made a note to check on this. By using NEMA data

and extrapolating, you're showing halogen shipments at

21 60 percent in the commercial sector and 40 percent in

22 the residential sector. A lot of that ­­ which is

23 impacting what we're saying right now. I'm concerned,

24 and we will check on it.

The way we collect our data, if you take a

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1 Home Depot or a Lowe's, that's counted as residential.

2 MR. FERNSTROM: Yeah. If I could add to

3 that, too, we take all of the rebate activity that we

4 do through those kinds of stores and split it into

small commercial and residential. So we call it mass

6 market, but clearly there are a lot of products

7 supplied through those outlets that go into small

8 commercial establishments.

9 MR. BROOKMAN: How do you split it?

MR. FERNSTROM: How do we split it?

11 MR. BROOKMAN: Yeah.

12 MR. FERNSTROM: I believe we underestimate

13 commercial. I think we estimate it at 15 percent. I

14 believe it's more than that.

MR. BROOKMAN: Susan, you had a follow­on

16 comment there.

17 MS. ANDERSON: That was pretty much my

18 follow­on.

19 MR. BROOKMAN: Okay. Steve. Go ahead.

MR. LEWIS: To finish up that, if anybody has

21 got any more precise data, anything that may help us,

22 we would appreciate it. These base assumptions in this

23 stage, the ANOPR, a lot of them are straw man from what

24 we've got and limited data. This is exactly what we're

looking for. Help us to see more clearly.

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1 MS. GUPTA: Yeah. Just as a clarification,

2 the 60/40 assumption is not based on NEMA shipments.

3 It's based on an NYSERDA study done of the incandescent

4 reflector inventory.

MS. HORNER: I'm still concerned that people,

6 you know ­­

7 MS. GUPTA: Yeah, of course.

8 MR. BROOKMAN: Steve Nadel.

9 MR. NADEL: Building on a comment Andrew

made, I agree there will be significant use of emerging

11 technologies. However, I don't think it's going to be

12 immune to the standard level. If you set a higher

13 standard and the price of the base case product goes

14 up, that's going to decrease the cost difference

between an incandescent product ­­ it might be an HIR ­

16 ­ and an LED or a CFL or something.

17 So I think you need to have some connection.

18 I'd only be guessing at what the connection is. But

19 to assume that the standard has no impact on emerging

technology seems a bit of a stretch.

21 MR. BROOKMAN: Paul.

22 MR. WALITSKY: One comment. I don't think

23 that the zero point in 2011 is correct because we're

24 already selling CFLs that can dim. They're going into

ceilings now. Not a big number, but they're being

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1 sold. So if it's not zero now, it's certainly not

2 going to be zero to start with in 2011 or '12.

3 MS. GUPTA: It's zero percent of ­­ I mean,

4 this ­­ sorry. This isn't ­­ it's not of the total

inventory of all lamps out there. It's just in 2011 we

6 calculate what the inventory is of covered IRL. Then

7 we say, taking those sockets, we project a certain

8 amount of growth from those sockets, and of that total

9 inventory we shift some of those towards emerging

technologies.

11 MR. BROOKMAN: I just got the word. We're

12 going to be booted from this room in about 15 minutes,

13 so make it through the rest of these slides.

14 (Laughter.)

MR. BROOKMAN: Keep going. No, I'm talking

16 about just the section through, what, 38, I guess. So

17 we need to keep going because they're literally going

18 to lock this place up and we want to be out of here by

19 then.

MS. GUPTA: Okay. Turbo. Okay. Similar to

21 fluorescent lamps, we have base case market share

22 matrices for IRL. Various assumptions are made to

23 populate these, and we'd like your input on them.

24 We look at three lumen packages in the

shipment model for incandescent reflector lamps, and

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1 they correspond to the three baselines analyzed in the

2 engineering and LCC analysis. We got these current

3 market shares based on just product availability, so we

4 definitely welcome input on them.

MR. BROOKMAN: Comments on the market shares?

6 Steve Nadel, please.

7 MR. NADEL: Okay. I'm going to make one

8 comment, then ask two questions.

9 MR. BROOKMAN: Are you going to get us out of

here in 15 minutes?

11 MR. NADEL: I actually have to make a six

12 o'clock conference call.

13 (Laughter.)

14 MR. NADEL: The comment, and I imagine Pam

may say something similar, it's pretty hard,

16 particularly in the residential sector, to do all these

17 great little market shares and ignore the BR lamps. So

18 I would encourage making it explicit rather than having

19 this, you know, dream world that there's no use of BRs.

I recognize, and I looked on ahead, that you guys did

21 do some projections.

22 One thing I'd request is, could you provide

23 the same type of charts on the alternative scenarios?

24 That will make it easier for us to review. It's quite

possible ­­ I haven't even looked at that one ­­ you

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1 know, we may recommend that the BR case become the

2 primary case just because there are BR lamps out there

3 and we need to account for them.

4 MS. GUPTA: So those market share matrices

are in the TSD appendix.

6 MR. NADEL: In the TSD? If you could even e7 mail us ­­

8 MS. GUPTA: Nine ­­ yeah, sure. We can

9 definitely e­mail them.

MR. NADEL: ­­ going to find them out of a

11 thousand pages ­­

12 MS. GUPTA: Appendix 9 ­­

13 MR. RIVEST: No, they are on page 30. Go to

14 page 30.

MR. NADEL: Thirty of what?

16 MR. RIVEST: This presentation.

17 MR. NADEL: Oh.

18 MS. GUPTA: No, that's the main scenario.

19 It's not the ­­

MR. NADEL: That's the main scenario.

21 MS. GUPTA: It's not the ­­ he's asking for

22 the BR lamp scenario.

23 MR. RIVEST: Oh. This scenario does not

24 include ­­

MS. GUPTA: The BR shift.

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1 MR. RIVEST: ­­ the BR shift. Okay. Sorry.

2 MR. NADEL: Okay. One other question before

3 I leave. I know you're asking for input on trial

4 standard levels. Is it DOE's intent to have separate

trial standard levels for fluorescent and incandescent

6 or are you looking somehow to align the two together,

7 so Trial Standard 1 has to line up across the two?

8 MR. BROOKMAN: Mike Rivest.

9 MR. RIVEST: My gut feel is that there isn't

that elasticity between the fluorescent and

11 incandescent markets that would require us to do that.

12 MR. NADEL: So there will be two separate

13 sets of trial standards. I agree. I just wanted to ­­

14 MR. RIVEST: Okay.

MR. BROOKMAN: What Mimi's going to do now is

16 she's just going to provide the illustrative comments

17 on these remaining slides so you get the flavor for

18 them and not the full content, so that you can then go

19 back to your respective offices and then comment fully.

Okay?

21 MS. GUPTA: Sure. Okay. So, to develop the

22 base case market share matrices, we make various

23 assumptions regarding the residential stock and the

24 commercial stock product mixes. Generally, we

incorporate some HIR technology in the commercial stock

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1 but not in the residential stock.

2 So, here we see the shipment forecast in the

3 commercial and residential sectors. We see decreased

4 shipments over time due to the penetration of emerging

technologies and the shift towards longer­lived HIR

6 lamps in the commercial sector.

7 In terms of the standards case shipment

8 methodology, the main difference between the base case

9 and the standards case IRL shipments is the

incorporation of standards case market share matrices,

11 similar to fluorescent lamps, that characterize what's

12 the product mix of the inventory from 2012 to 2042 with

13 the standards.

14 To develop those market share matrices, we

incorporate several possible scenarios. One is a main

16 scenario, which assumes that all IRL consumers continue

17 to purchase regulated IRL products. It's basically a

18 roll­up. They roll up to the lowest ­­ or, the next19 lowest efficacy available.

A second scenario is the 65­watt BR

21 substitution sensitivity, which Steve was speaking

22 about earlier, in which we account for, in the

23 standards case as the IRL lamp price goes up, people

24 are going to shift to BR incandescent lamps that are

exempted from the standards. The only ­­ the one lamp

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1 that we take into account is the 50­watt PAR baseline

2 lamp will be shifted towards the 65­watt BR lamp.

3 The third scenario is a 10 percent lumen

4 increased sensitivity, which addresses the idea that

residential consumers may not necessarily know to

6 purchase a reduced wattage lamp and may purchase

7 instead a same wattage or even greater wattage lamp to

8 replace their base case lamp. That would result in an

9 overall increase in lumens and lower energy savings.

I'm going fast, Doug. I'm going fast.

11 Here is an example of the standards case

12 market share matrix used for IRL, and in the

13 residential sector as well.

14 MR. BROOKMAN: So, of course, no time to

comment on these now, but the Department would really

16 welcome your careful scrutiny on these numbers and your

17 written comments.

18 MS. GUPTA: Now, to calculate the national

19 energy savings, we use the product stock by design, the

unit annual energy consumption established in the

21 energy end use, electricity site­to­site conversion

22 factors calculated from AEO, and an HVAC interaction,

23 which we got from the 2000 ballast rulemaking, and a

24 rebound rate which we estimated in both the commercial

industrial and residential sectors.

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1 We ask for comment, but later.

2 To calculate the net present value, we take

3 our shipments by product design, our per­unit installed

4 cost taken from the LCC and the product price

determination, electricity prices, a discount rate of

6 seven and three percent real, which are ­­ both of

7 which are used to calculate two different MPVs.

8 In addition, we also take into account

9 residual value of the remaining lifetime of lamps left

at the end of the analysis period, similar to what the

11 LCC does.

12 Here are just some sample results of the

13 general service fluorescent lamp MPV and national

14 energy savings. As you can see, generally, most

standard levels are cost effective and we have

16 increasing energy savings.

17 Here is the national energy savings and MPV

18 for incandescent reflector lamps in the main scenario.

19 Again, we see increasing MPV and energy savings.

Thank you.

21 (Applause.)

22 MR. BROOKMAN: So I never recall going this

23 late with one of these meetings before. It's testimony

24 to your interest, your expertise, and also your

endurance. So, thanks to all of you for hanging in

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1 here.

2 Back to Ron Lewis for closing remarks.

3 Closing Remarks

4 Ron Lewis

MR. LEWIS: We tried our best to reach a

6 compromise here between those that wanted to end today

7 and our schedule. We were trying to allow time to

8 fully talk through everything. We hope we didn't rush

9 too much. We were trying to accommodate both.

So we are going to be here in the morning.

11 We're going to still discuss the rest of the agenda and

12 take questions tomorrow morning.

13 MS. HORNER: Time?

14 MR. BROOKMAN: Nine o'clock.

MR. LEWIS: Nine o'clock in this room.

16 MR. BROOKMAN: Right here in this same room.

17 PARTICIPANT: According to the agenda, just

18 for logistics so we can tell, it looks like you have

19 another hour scheduled beyond this. Is that about

right? So we'll be done around 10 tomorrow, you're

21 thinking?

22 MR. LEWIS: If we could allow maybe two

23 hours.

24 MR. BROOKMAN: There's also an overview

segment, and who knows ­­

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1 MR. LEWIS: Just to make sure. We pushed a

2 bunch of things that were supposed to be covered today,

3 and this is all to get your input and to have a

4 dialogue. So I'd rather not be compressed again

5 tomorrow if we've got some time.

6 MR. BROOKMAN: Probably, safely by noon.

7 MR. LEWIS: Yeah. But I appreciate everybody

8 hanging in here and your input. We're trying to do the

9 best we can to fully discuss this. We've got the

10 comment period. We really want to get it right.

11 So, thanks for hanging in here today. Those

12 that can still be with us tomorrow, we appreciate it

13 and look forward to see you tomorrow.

14 (Whereupon, at 6:00 p.m., on March 10, 2008,

15 the meeting was adjourned, to reconvene at 9:00 a.m.,

16 on March 11, 2008.)

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REPORTER'S CERTIFICATE

This is to certify that the attached proceedings
 

before:

UNITED STATES DEPARTMENT OF ENERGY

In the Matter of:

PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE

FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND
 

GENERAL SERVICE INCANDESCENT LAMPS
 

AND
 

ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE
 

FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS
 

Were held as herein appears and that this is the
 

original transcript thereof for the file of the

Department, Commission, Board, Administrative Law Judge

or the Agency.

Further, I am neither counsel for or related to

any party to the above proceedings.
 

Debra Derr

Official Reporter

Dated: April 5, 2008
 

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